Since BSA requires banks to gather information for CTR reporting on individual(s)who present transactions in cash in excess of $10,000 at a teller window, would the bank be required to gather that same information when a business customer's money bag is dropped off at a teller window or the drive-thru destined for the money vault? Are we required to gather or attempt to gather information on the individual presenting that transaction before we know the amount of cash in contained in the bag?

I would suggest to those commercial customers who send their money bags, to drop them off in the night drop. I beleive if they are informed that the bank is required to identify the runners who come in with the money bags if the cash in the bags total more than $10K, they will deposit cash under the reportable limit and the bank may inadvertantly help the customer structure the deposit.

It is a sticky situation. Since the runner who comes in is not part of an armored car service, the best suggestion is to inform business, who do not want their deposits verified when the money bag is dropped off, to utilize the night drop.

These are only my opinions...I know there are other suggestions out there, but thought I would put in my 2¢ worth... Hope this helps...

You may also want to discuss the need for CTRs with your contact at the business. If there will be a limited number of runners (probably), you can obtain proper ID in advance to reduce the time required when deposits are delivered. You also need to cover the bank's policy to reject cash transactions until proper ID is obtained. If the business explains the CTR requirement to its runners and demands their cooperation, transactions can be handled without hassle.

Be careful "suggesting to your customer to use the night drop". In your post you are also helping the customer structure by showing them how to avoid having to supply their info.

If the business won't provide the info on the runners and then you discover they have changed their deposit, file an SAR.

We do not accept deposits as "drop-offs" (and believe me, many have tried!) Customers may utilize the night depository or arrange for armored car shipments to our main vault (not to the local branch office).

CTRs are based on the bank's knowledge. If you know it, report it. (And if Suzy Teller knows it, the bank knows it.) So if Suzy sees the runner and knows a CTR is going to be required, the bank is responsible for documenting the information and reporting in on the CTR.

Knowledge is power...or a pain...something like that!

Are you able to do a Designation of Exemption on this business customer. If they meet the requirements for this, the need to file the CTR's no longer exists.