If a customer brings in say $700 in coins and just wants to exchange the coins for bills, do we need to track this in any way? My thought is no, but some employees are asking if we need to monitor this in case they were to deposit or withdraw cash later that would aggregate over the 10k limit. Currently we would only care if they brought in more than 10k in coins at once. Also if a customer were to bring in more than $1,000 in coins with the intent of buying a Monetary Instrument we would make them deposit the coin into their account and then withdraw it for the MI, to create a paper trail.

A coin exchange for bills is a transaction in currency with equal cash-in and cash-out amounts. If it, when aggregated with other currency transactions by or on behalf of the same person, exceeds $10,000 in or out, a CTR is called for, if the bank is aware of the combined total. So your employees are correct, if the bank has a means for combining the transactions for the purpose of determining whether CTRs are required.

Thanks John, we only run coin for our customers. I'm new to compliance and would like to know how you would handle monitoring this? We have some coin collectors who do bring in about $1000 in say dimes (looking for silver I assume) and then we have a little old lady bring in $10 in change from her purse. Should these be handled the same way? Or can we set a threshold so tellers don't have to run every small amount of coin thru a customers account?

Honestly, no, but only because the likelihood that the LOL will have other cash transactions of over $9,990 the same day is slight, although if she did bring in a deposit for $9,990 first and then brought in $20 in loose change to swap for bills, I'd imagine someone would remember, and you'd have to file (and consider the likelihood the LOL is structuring!).

Back when I was running my old bank's ATM program and our BSA compliance program, I had my branches post to a central log any ATM cash deposit over $100. We'd see if anyone with teller cash deposits over $9,000 somehow made it over the $10,000 hump. I think we identified one CTR in five years that way.

If the guy bringing in $1000 in dimes also owns a business that banks with you and makes cash deposits, I'd be paying attention. Otherwise, I don't really think you've got a need to be concerned.

JoeA - we've developed some very simple, effective methods to capture both currency exchanges and ATM cash deposits for CTR reporting purposes. If you want to send me a PM with your contact info we can discuss in more detail.