We provide our customers with a "bank" courier to pick up their deposits. On occaision there will be a reportable CTR transaction. How should the CTR be completed for the conductor? It is not an armored car, just a courier, does it fall in the same category? Or do we indicate multiple transactions since we do not know who completed the deposits for the courier to pick up?

If it's a bank courier, the courier is your agent and stands roughly in the position of the teller who processes an "in-person" transaction. The conductor of the transaction is whoever hands the transaction to the courier, and the courier will need to obtain Section B information on that individual.

That is an interesting spin... Now I need to make sure that the courier's BSA/AML training is sufficient and that we have proper procedures.

Never a dull moment! Thank you for the advice.

You let bank employees pick up cash deposits? That's kind of scary.

Agree with Dolly. In addition to checking BSA procedures and training, check that the bank is covered for this activity in bonding and insurance.

And depending on your charter, make sure you have a chartered mobile branch.

Oh! the OP's profile says a national bank...this is a mobile branch and must be approved as such (and should not operate until it is approved - if it has not been until now.)

Personally, I think this is very dangerous. That is what Armored Carriers are for. I don't think it's a good idea to put bank employees in these types of situations. If something happens, you can bet that family members will be looking to sue the bank.

I don't think banks that allow this have thought it through.

We once acquired a bank that had the bank's name all over the courier cars. They were furious when I insisted it be removed AND that the couriers absolutely NOT transport cash. They complied once I offered to establish a conference call with the bonding company to discuss the matter.

I know this is an old thread. However, Is this not against fed regs? I did not think you could have a bank employee courier and transport items for customers because of an unfair competitive edge. This is a huge question for me as I have been trying to find an answer for quite some time.

Depends on the branching laws of your state.

If it is a national bank, it is a mobile branch and must be approved as such.

The thread illustrates some landmines, but you want a nuclear bomb too? It's an indefensible practice...