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#2007333 - 04/10/15 02:21 PM
Cash in Safe Deposit Box
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Member
Joined: Dec 2005
Posts: 61
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We have had to drill a safe deposit box for abandonment and inside we found $53,000 in cash. Do we need to complete a CTR or SAR, or simply just turn it over to the State?
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#2007368 - 04/10/15 03:43 PM
Re: Cash in Safe Deposit Box
crazed
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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If it's not too late, do not comingle the bills with your other cash; keep them in the box where you keep other abandoned property, at least temporarily. If you do the research JACFSB suggested, the bills may be able to tell a story of their own.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#2007568 - 04/11/15 05:29 PM
Re: Cash in Safe Deposit Box
Elwood P. Dowd
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Gold Star
Joined: Jul 2011
Posts: 413
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What Ken said; some of those bills/coins may be worth more than their face value (even if only in the mind of the absent box owner or his/her heirs). Co-mingling or turning the $$ into a Cashier's Check could become very painful if someone attempts to claim the box contents down the road.
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Nothing difficult is ever easy.
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#2007690 - 04/13/15 06:13 PM
Re: Cash in Safe Deposit Box
crazed
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New Poster
Joined: Apr 2015
Posts: 23
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I would reach out to FinCen on this, we hade a similar situation (13k in cash) and they informed us to file a CTR. The customer later claimed the money and we in return had to file another CTR.
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#2007716 - 04/13/15 07:09 PM
Re: Cash in Safe Deposit Box
crazed
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Power Poster
Joined: Jul 2006
Posts: 4,457
New York City
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^ The advice that the FinCEN personnel who answer the Helpline give continues to amaze me.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu
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#2007823 - 04/14/15 12:47 PM
Re: Cash in Safe Deposit Box
crazed
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New Poster
Joined: Apr 2015
Posts: 23
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The reasoning they gave was that it was foreign cash coming into the system "so it needs to be reported on"..makes sense (I guess), but I see where you all are coming from.
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Keep Calm and BSA On
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#2007826 - 04/14/15 12:52 PM
Re: Cash in Safe Deposit Box
KeepCalm
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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There is always less danger in telling someone they must do something than there is in saying it's not necessary...
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#2007838 - 04/14/15 01:15 PM
Re: Cash in Safe Deposit Box
crazed
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Power Poster
Joined: Jul 2008
Posts: 4,797
You are here
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so what account had suspicious transactions in it and when?
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Opinions can be considered as coming from anywhere but my employer.
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#2007880 - 04/14/15 02:15 PM
Re: Cash in Safe Deposit Box
ACBbank
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Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
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^ The advice that the FinCEN personnel who answer the Helpline give continues to amaze me. I had FinCEN tell me I had to file a CTR on a customer who had their debit card stolen & money withdrawn from an ATM in Mexico. They made me file the CTR on the customer even though we knew they did not benefit from the cash.
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My opinions are my own, and not that of my employer.
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#2007891 - 04/14/15 02:40 PM
Re: Cash in Safe Deposit Box
KeepCalm
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Power Poster
Joined: Nov 2001
Posts: 6,719
PA
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The reasoning they gave was that it was foreign cash coming into the system "so it needs to be reported on"..makes sense (I guess), but I see where you all are coming from. If I understand correctly, it sounds like when you find cash in an abandoned box, that you are crediting that cash to some kind of general ledger or bank owned account?
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#2007896 - 04/14/15 02:46 PM
Re: Cash in Safe Deposit Box
crazed
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New Poster
Joined: Apr 2015
Posts: 23
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Yes it was into a general ledger account, then once he came in, they pulled the money back out of the account triggering the second CTR. Kind of a unique situation, interesting to learn that it happened at another bank
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Keep Calm and BSA On
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#2008036 - 04/14/15 06:32 PM
Re: Cash in Safe Deposit Box
crazed
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Power Poster
Joined: Nov 2001
Posts: 6,719
PA
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That completely changes the dynamics on the CTR question. In your scenario, you are transacting in cash, and a CTR would be appropriate. But I would suggest that it was not the best way to handle the inventory.
By crediting the cash to a GL account, you are causing the bank to take those funds into its ownership, which should not be done. They are not funds on deposit, and they are not assets of the bank.
Typically, when a safe deposit box is abandoned and drilled, the contents of the box are inventoried, sealed, and secured in their entirety and in their extant form. The only time cash should be converted is in preparation for escheat.
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#2008046 - 04/14/15 06:51 PM
Re: Cash in Safe Deposit Box
crazed
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10K Club
Joined: Jul 2001
Posts: 84,498
Galveston, TX
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I agree, Your external accountants would most likely not be too pleased with your process for the reasons JacSB indicates.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2008059 - 04/14/15 07:21 PM
Re: Cash in Safe Deposit Box
WonderWoman
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Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
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^ The advice that the FinCEN personnel who answer the Helpline give continues to amaze me. I had FinCEN tell me I had to file a CTR on a customer who had their debit card stolen & money withdrawn from an ATM in Mexico. They made me file the CTR on the customer even though we knew they did not benefit from the cash. Head.DESK.THUMP! That is a true WTH moment.
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CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
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#2008098 - 04/14/15 08:18 PM
Re: Cash in Safe Deposit Box
JacF
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Gold Star
Joined: Jul 2004
Posts: 345
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That completely changes the dynamics on the CTR question. In your scenario, you are transacting in cash, and a CTR would be appropriate. But I would suggest that it was not the best way to handle the inventory.
By crediting the cash to a GL account, you are causing the bank to take those funds into its ownership, which should not be done. They are not funds on deposit, and they are not assets of the bank.
Typically, when a safe deposit box is abandoned and drilled, the contents of the box are inventoried, sealed, and secured in their entirety and in their extant form. The only time cash should be converted is in preparation for escheat. Exactly this!
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#2008201 - 04/15/15 02:49 PM
Re: Cash in Safe Deposit Box
crazed
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Gold Star
Joined: Nov 2005
Posts: 346
Mid-Atlantic
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To share a story...back when I was a teller in the late 1990s, we had a lady in her early 90s always put cash in her safe deposit box. She had the biggest box size, and eventually got another box of the same size. She would withdrawal cash, redeem CD's, savings bonds and the like and put all her cash in the boxes; stating that she didn't want her children to have to pay taxes on their inheritance.
She passed away a couple of years later. I still worked for the same bank, but a different branch, and had heard that her son came in (joint owner of the boxes) and emptied the cash from both boxes into a large briefcase - over $150,000 cash - and took it home.
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