Answer:
If that requirement is cooked into your board approved BSA/AML policy, it would need board approval. But if the information is not really needed, why are you collecting it from all of your other commercial customers?
Conductor Information for Aggregate CTRs
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Question:
We have a business customer whose deposit runners are refusing to provide their information for us to collect as conductors of cash transactions. These are typically smaller transactions, but we require a conductors information on all cash transactions over $1,000 for aggregation reporting purposes. They previously banked at a larger regional bank which did not require these runners to provide identifying information. Are we OK to make an exception for this business client unless it is a CTR reportable transaction?
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