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BSA Log - Convenience Signer Deposits

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Question: 
My bank maintains a log of transactions $2,500 and over. We have a customer that maintains a package store account and a beer store account. He is the sole owner of the two checking accounts and his daughter is a convenience signer on both accounts and makes the daily deposits. Monday's deposits include weekend sales and will consistently be over $2,500 and as a matter of additional business she will make a cash deposit to her personal account. This is not to say that the cash going into her account is from any sales proceeds from the package or beer store. We obviously report the cash deposits over $2,500 going into the business accounts, but we are not sure if we should report the proceeds being deposited to the daughter's personal account. At this point we are not suspicious of the proceeds going into the daughter's personal account and we are just wondering if the aggregate deposit to the business accounts and the deposit to her personal account should be logged in the report.
Answer: 

Your procedure of logging cash deposits over $2,500 is purely a bank procedure and is not required by any regulation. How you choose to manage that process is up to you. However, if the daughter deposits more than $10,000 in cash on any business day to any combination of accounts (business and personal) a CTR must be filed.

First published on BankersOnline.com 1/19/09

First published on 01/19/2009

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