Questions and Answers

When a customer starts asking questions about how much they can deposit without any paperwork, what do we tell them? Can we refer them to any consumer resources?

The situation you describe can be tricky.  The regulators do expect that you limit your conversation with customers as to how or why currency transaction reports (CTR) or suspicious activity reports (SAR) are being filed.

With respect to the CTR, providing the customer with information regarding the $10,000 reporting threshold could put you in a position of helping the customer structure their transactions to avoid the report. Structuring is specifically prohibited under the BSA regulations.

With respect to the SAR, the law specifically prohibits the notification to any person that is involved in the activity being reported on a SAR that the activity has been reported.

Unfortunately, there are no easy answers regarding how to get around a customer who questions what you are doing.  Try to be as vague as possible and explain that certain transactions require additional paperwork and that you are prohibited from providing information regarding the paperwork. Rather than complete the CTR in front of the customer, it might be useful to collect the information on a worksheet and complete the CTR at a later date.  The worksheet may appear less threatening to a customer than the form itself.  Also, be sure to train your staff to not give out too much and to pull in a supervisor if things get sticky. Finally, if a customer withdraws their transaction once you begin work on the CTR, consider filing a SAR.

(Posted: 05/22/2008)

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Learn more about Bank Secrecy Act compliance requirements with the Deposit Accounts Manual. 

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