The bank president told a local church they could deposit coin collected at the various schools and churches for Easter. Problem- the church does not have an account here. We do not provide banking services for people without accounts. Since I discovered this - they have made two cash deposits (1) Approx. $2,300 and the other approx(2)$1,500. We collected no information on the person dropping the money off, but I am asssured he is the bank president's neighbor.

The rep for the church said they don't want to open an account because the collection ends Easter Sunday so the last deposit will be Monday. What do I do now? Do I not accept the Monday deposit? Require ID and accept Monday's deposit? Help!

If they don't have an account, where is the 'deposit' going?

The cashier check GL. Then the teller is giving the rep a cashiers check payable to the church. (Sorry - I should have explained that).

So they are buying a cashier's check with coin?

That isn't a deposit.

Yes you are right. I'm sorry I am doing 100 things right now. Let me try again.

Here it is a guy is collecting donations for the church through the school and bringing in bags of coin. He takes teh coin to the teller who runs it through the machine and tells him it is $X. He then asks for a cashier's check which the teller does. Our policy does not allow for this because he nor the church have accounts at the bank.

I hope that explains it better. Again, I am sorry.

I really dont see a big problem here. It appears you have a policy of not selling cashiers checks to non-customers.
Policies are general guidelines and certain bank officers can always make exceptions. Especially the President.

However, if the CASH purchase of cashiers check is between $3000 and $10,000 in any one day it should be logged in your MIL. I can't tell from the fact if you exceeded $3000 in one day. However, it sounds like your President at least knows the guys at the church. If you took in over $3000 in cash in any single day for purchase of a monetary instrument/s simply contact these guys and get the information you need.

I don't see dealing with a non-customer as your problem. It's the BSA requirements that you need to worry about.

I think you have an issue in that you have broken your own policy.
And why would they not take this coin to their own Bank?
I think you would need to document the whole incident, explain why the service was offered to a non customer, - and then perhaps add something to your policy to accomodate these situations in the future.
I am not sure that I agree 100% with WyoRockies statement that policies are general guidelines and officers can always make exceptions. I think possibilities of exceptions have to be forseen and written into your procedures, instead of doing it the other way around, which is what is happening in this case, and they should run it by the compliance officer first. Compliance should know of these things before they happen, not after the fact.
IMHO.

If a bank makes a one-time exception for a charitable group the examiners are not going to care. That's the beauty of community banks. You can sometimes do things that the Larger banks can't. You have some flexibility and can act quicker. The fact of the matter is that community banks often make "exceptions" for certain situations. At least the ones I have worked at, and they are some of the finest in the country.

That being said, if a bank repeatedly breaks it's own written policy, the examiners are going to point out this fact and tell you to either cease the activity or change your policy. I agree with Magic City though that if your President or Execs plan on making more exceptions to this or other policies you should have a provision regarding the possibility.

Again, check the amounts on the incoming cash to make sure you cover your BSA requirements.

Good luck!

I've seen community banks written up for one broken policy. We need to review our policies and make sure we have "wiggle room". Build in controls where certain exceptions may be approved by a senior level officer, BSA officer (whomever) who can appropriately weigh the risks of these case-by-case calls.

Documenting the exception to your policy would probably be sufficient for an audit trail. We designed a form to document any exceptions to policy. We have the officer making the exception and the compliance officer sign the form. Our frontline people really like the form. It also makes officers accountable for the exceptions they approve.

Tlopez! What a great idea! Is the form sharable?

my policy says we do not sell to non-customers (cash) ... then provides the provision for an exception.

• Should the Bank sell a cashiers check to a non-customer for cash (any exceptions must be approved by the BSA Officer or other member of Senior Management), the Bank will gather the following additional information on the purchaser:
o Physical Address
o Driver’s License or other Identification acceptable for Large Currency Reporting
o Tax Identification Number
o Date of Birth