Question & Answer

Question: We are having a hard time convincing our branch office people to fill out the $3,000 to $10,000 log carefully and forward it to us at the end of the month as they are supposed to. Can you give us some examples or horror stories about not doing this as is required by the regulation that would help with our "convincing"?

Answer: This is a tough one! You see, there have been very few-and I will repeat, VERY FEW instances where these records have been requested or used. IRS investigators don't seem to know these records are available, nor what to do with them. As a result, the examiners and regulators are not paying much attention to them either. It doesn't take our people on the front line long to catch on to the "non-importance" of this exercise.

We're just as sure, however, that some regulatory agency will use this as a "hot" button, and start cracking down.

The best we can offer is to talk to your audit folks and make this a part of their regular office audit. Our own auditors are much tougher on us than the examiners or regulators ever thought of being. That may help.

Of course, we'll keep our ear to the ground for the first institution to get the book thrown at them for non-recording-have no fear, it'll happen somewhere down the line!

Copyright © 1992 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 3, No. 4, 8/92