Wouldn't cash in a Safe Deposit Box be some what similar to keeping a large amount of cash under the mattress? I believe it is the customers choice as to where they keep there cash. Why they wouldn't want to be earning interest on such a large amount is not logical to me. Safe Deposits are fire proof right? For that reason alone I would rather have a customer keeping money in the SDB then under the mattress.

SAR or not, if it is an older customer, try to figure out the mentality of the person or maybe there is a family emergency. All reasons are not bad. Take the 30 days to file a SAR to heart and use them!

Let's step back a second and think about this. If the cash was from illegal activity or the customer was attempting to hide the funds, the customer never would have deposited the cash in the bank in the first place.

I once had a bookie open a box at a branch. He would come in once per month to use his box. Turned out he was holding cash in the box. Guess he thought it was safer than under the mattress.

The point is, we never knew, nor even suspected the cash was in there.

Given these circumstances, I don't think you have a SAR filing here.

Mental and emotional problems sometimes DO lead to strange financial behavior. We once had a guy who withdrew a hefty sum of cash in $1 bills. A few days later, he brought it back and redeposited it. We later learned that he had dumped it out on the floor and rolled around in it for kicks.

Did the teller know that before she counted all those bills back into her drawer?

I don't recall--but the event shed new light on the possible benefits of money laundering!

JacFSB - I think I'm going to be sick! (I don't know that I'll ever eat Chinese again).

Using some heavy duty detergent!

We've all heard really icky stories from tellers (or maybe had the experience ourselves) of where customers get the cash they're depositing. I wonder sometimes if the location the cash comes from warrants a SAR!

I once had a customer who brought $$ in that smelled like a litter box...and another customer that was a male stripper that used to bring in his $1.00 bills (don't want to know where those were stuffed!!!!)

Okay, let's put a little twist to the situation. An older lady cashes in cds as they mature and puts the cash into a safe deposit box that she shares with her kids. Suggestions to use a cashiers check instead of cash reveals that she wants her kids to have access to the cash without going through probate. So now we have knowledge that the transaction is designed to evade taxes in the future. However no crime has occurred. . .yet. Is a SAR warranted? While it is unusual pattern for this person, until they actually evade probate, it's not illegal. What's your opinion?

I think that the transaction would only warrant a CTR b/c cash was withdrawn greater than 10K. The buck stops there!!!!!

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So now we have knowledge that the transaction is designed to evade taxes in the future

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Do you really? Maybe she wanted to provide immediate access to her children vs. waiting for probate for what she thinks are valid reasons. Estate taxes are complicated and an assumption the intent is future tax evasion on funds that you don't even know for a fact will be subject to taxation does not warrant an SAR. A CTR s/b filed if applicable.

The bottomline is this: Customers can be very strange, but that is not reportable unless the resulting event is specifically covered within regulations. We are not part of the government; we are not in the business of reporting strange behavior unless that behavior involves a transaction that is truly suspicious, not simply strange.

Customers have a right to be strange and banks should not be in the business of reporting that fact.

Grist -
I think I said (more than once) that the mere act of placing cash in a SD box box does not make the transaction reportable. What I said was, maybe you need to ask "why". I once had a customer who came into the bank and withdrew a huge sum of cash. He then sat at my desk folding each bill into teeny, tiny little squares. He then placed the money in his SD box. I asked him why he was doing that, and he told me he was planning to smuggle the funds out of the country! (He wasn't kidding!) While the mere act of placing the money in his box didn't make it suspicious, what he TOLD me did! All I was trying to say (apparently unsuccessfully) is that you have knowledge or reason to suspect that an activity is illegal, you should report it.
Leslie

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Suggestions to use a cashiers check instead of cash reveals that she wants her kids to have access to the cash without going through probate. So now we have knowledge that the transaction is designed to evade taxes in the future.

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You can designate a POD on an account to avoid probate, that doesn't mean they are avoiding taxes.

Andy, years ago when I worked in a branch I also heard that "myth" about cash in a safe deposit box. I wonder where the idea that it was a law came from?

Part of what you said was:
Before I posted my reply, I checked with our BSA Offocer and asked her if a SAR should be filed in the circumstances stated by the original poster. She felt that it could be suspicious, and as such, should be reported. Truthfully, a customer walking out the door with large sums of cash on a regular basis could also be suspicious and reportable.

You did not include "Why" at that point as an element. Even if you pursue "Why," and the customer tells you that it is none of your business, it appears that you would start writing it up an SAR because the customer did not 'appropriately' respond to your question.

I’d say that the BOL consensus on this subject/thread is clear, no SAR report, except at your bank in MD.

Grist- I'm nominating you for a Vegan2 award. Leslie has been a valued member of this forum since its inception and we've always allowed posters--especially those who do business in their own names and do not hide behind a screen name or post anonymously--to express themselves fully, without the kind of harassment that's developed in this thread. I, for one, always look forward to the analysis and insight Leslie's posts bring to our discussions.

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I’d say that the BOL consensus on this subject/thread is clear, no SAR report, except at your bank in MD.

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I accept the award, but what do I get?

Are you some sort of knight in shining armor? From Leslie's posts it appears that she can take care of herself.

I you, and Leslie Croaker, thanks for sharing such warm thoughts during the holidays.

Grist,

I think the consensus of the last several posts is that you are being rude and it is not appreciated. Let's be professional and not pursue this any further.

I'm sorry, I have to say, I have not been offended by anything in this post. I understand why people may be upset though.I don't understand why we can't just get along! But of course we don't live in a perfect world (where the new Powerball winner lives). I always remember the good posts Grist has made. The posts I have seen of Vegan, none of them were productive. Grist is definetly not a Vegan.

being rude

For my continuing enlightenment, please point out the "rude" part.