Cashing Third Party Checks

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Question:

While cashing a check issued by its customer to a third party, is it mandatory for the paying bank to obtain the Social Security Number of the payee apart from photo ID details? If not, and if the transaction results in filing a CTR, what is the recourse?

Answer:

If the transaction by itself triggers the filing of a CTR, the bank is required to obtain the information necessary for completion of the CTR. That information includes a Social Security number or ITIN for those individuals who have them.

If the transaction is for a smaller amount, any requirement for obtaining the SSN or ITIN depends on the bank's policies and procedures. Some banks have procedures calling for that information for transactions of $3,000 or more, for example, to be used if aggregated transactions would trigger a CTR filing.

First published on BankersOnline.com 8/02/10