Question & Answer

Question: We keep a log for transactions for over $3,000, but once we exempt them, do we have to keep the log on over $3000 in cash for customers on the exempt list under Tier II?

Answer: You'd be surprised at how often we get questions on the required "over $3000 in cash log". The fact of the matter is there is no longer any requirement to keep such a log. This rule has been dead for over two years now. As long as there is a trail of paper or traceable records of the transaction somewhere in your system, you no longer have to keep the $3,000 log. What we've found, as branches are examined, is that so much training went into keeping the log that it helps with audit and recordkeeping, so many financial institutions just left the procedure in place. (The old - "If-it-ain't-broke,-don't-fix-it" syndrome!) So the answer is, no - you don't have to keep a log on over $3,000 transactions for customers on the exempt list. But I'll bet you do anyway!

Copyright © 1999 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 9, No. 8, 9/99