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Armored Car Service-Conductor Info for CTR

Answered by: 
John Burnett
D. Trent Fleming
Ken Golliher

Question: 
During the Top Gun 1st day session presentation from Tom Fleming @ FinCEN, the subject was brought up about bank customers who individually contract with armored car services instead of using a bank contracted service are required to provide conductor information for the CTR form. We have two customers who use a national armored car service which also happens to be the same service that the bank has contracted with. When the monies are delivered to the bank for these two individual customers by the armored car driver, they are refusing to provide their personal information as the conductor. We circled back around to the national armored car representative for our bank and they are stating that they don't feel that the armored car driver should have to provide their personal information as they work for the armored car company and not the individual customer who is receiving credit. So the question is, do we refuse to accept further deposits from a long time customer because of this issue? Has FinCEN provided any further communication regarding this situation? I would imagine we are not unique to this situation, however, as I stated above, these two customers are using a nationally known armored car service, not a company that is not well established in this type of service. Any and all information would be greatly appreciated.
Answer: 

Answer by John Burnett: FinCEN has not provided further information and, from what I understand, has no plans to do so. The interpretation that is causing all the commotion is a simple restatement of the standard CTR requirements. The fact that the industry moved away from the paradigm in which deposits were collected by the bank's armored car agent toward the paradigm in which depositing companies contract with the armored carrier changed the agency relationship.

Your bank has a choice. It can continue accepting deposits under the present arrangement and filing incomplete CTR information (sans the information that the armored car representatives refuse to provide); you can continue working on the armored car company to extract compliance from them; or you can make your problem your customer's problem and try to leverage that relationship to wring compliance out of someone.

Answer: 

Answer by Ken Golliher: Please call the Helpline and ask them what you are supposed to do in this circumstance. Then, write a memo to file regarding what they told you. Then, do it.

They have a stock answer that is pure improvisation on their part, but you need to get it directly from them.

First published on BankersOnline.com 4/9/12

First published on 04/09/2012

Filed under: 
Compliance
Security
Filed under compliance as: 
FinCEN
IT
Filed under security as: 
FinCEN
IT

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