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commission of violations of federal law or as part of a
The letter report to the Director should accompany the pencil
The department of the Treasury issure Requestering (Part 103. Tille 31 CFM effective Jury 1 – 1977 in implement Titles I and II of Public Law 91 908 The RegulatNET as revised, require banas i
Report to the customs authorities, shipments time from a print musicle the linnec? Nates of curme y de traietary ing wonents in Embents in Pocess of 83 006 **
4 Retam for two years certain other bane records relating to demand deposit acrounes.
5 Secure a social security of 181paver identification number with respect to each account openient after June 30 1972 or maintain a isi laxed to provide a number, and
• Roser to the 195 currency transactions of more than $10.000 unas pompier
1 Mantan in a cereal he requires records of exemptions grantes corten Queerlying assoul accounts
Under certain circumstances, the Regulations provide civil and criminal penalties ie the lature to maintain the required rec
The examiner should determine that the bank has estateshed an adequate system in denkstying comment transactions and too mturing that they aNO LEIDENH reported and 21 that the employees who normally come into contact with the covered transactions are properly instructed as to the responsibility with respect to the system inadequacies in either of these two areas should be directed to the attention of management
The lothang Guestions are designed in bacarian coonpuence with the regulations. The exeren should complete the questions result of personal verification of records and reports, as well as observations and statements made by bank management REPORTS REQUIRED TO BE FILED
led on information obtained as a
1 (a) Except for shipments made through the postal service, or by common carrier, and certain shipments involving established depositors, does the bank hile a Report of international Transportation of Currency or Monetary instrument (Form 4790) whenever it ships to or receives from a point outside the United States currency or other monetary instruments, on any one occasion, in an aggregate amount exceeding $5.000: (5103 23) (b) Does the bank file a Currency Transaction Report. (Form 4788), of each deposit, withdrawal, exchange of currency or other transfer by, through. ar to this bank which involves a transaction in currency, not exempted, of more than $10,000 in accordance with the regulations? (§103.22)
(c) Does the bank maintain a list of those customers whose transactions have been exempted from the requirements of section 103 22 GENERAL RECORDKEEPING REQUIREMENTS'
2. Does the bank retain a record of each extension of credit over $5,000 except those secured by an interest in real property? (§ 103 33)
3. Does such record contain the name and address of the borrower, the amount, the nature and purpose of the loan and the date thereal? (§ 103 33)
4. (a) Does the bank attempt to obtain a laxpayer identification number for all new accounts? (§ 103 34)
(b) With respect to Certificates of Deposit (issued or redeemedi) does the bank maintain a record of the date of transaction and a description of the instrument as well as the customers name, address, and taxpayer identification number. also, when Certificates of Deposit are issued, the method of payment ($103 341
(c) Does it keep a list of those customers from whom it has been unable to obtain a number after making a reasonable effort? (§103 34)
5 Does the bank with respect to each deposit account retain the original or a copy of the following. (5103 34)
(a) Each document granting signature authority over such accounts? (Signature cards should be retained for five years after accounts are closed.) (b) Each statement ledger card or other record on each account, showing each transaction with respect to that account?
(c) Each item over $100 charged to deposit accounts, unless exempted by the Regulations?
6. Does the bank relain for two years certain other bank records relating to demand deposit accounts sufficient to reconstruct a demand deposit ac count and trace a check in excess of $100 deposited in such account through its domestic processing system or to supply a description of a deposited check? (4,103 34)
7 Are required records accessible within a reasonable period of time? (4103 36)
SPECIAL REQUIREMENTS FOR FOREIGN TRANSACTIONS
■ Does the bank retam a record of each instruction it gives or receives regarding a remittance or transfer of lunde, currency, etc., of more than $10,000 sent outside the United States? (§ 103.33)
9 Does the bank retam a copy of each item, including checks, drafts, or transfer of credit, of more than $10,000 remitted or transferred outside the United States? ($103 34)
10. Does the bank retain a record (letter of transmittal, cash letter or application for a draft or transfer, etc.) or each remittance or transfer of funds, or of currency or other monetary instruments, checks, securities, or credit, of more than $10,000 to a person, account or place outside the United States? A complete description is required in certain instances, the records retained to satisfy the requirements referred to in kems 9 and 10 above will also salisty this requirement. ($103 34)
11. Does the bank retain a record of each check or draft in an amount in excess of $10,000 drawn on or issued by a foreign bank which the domestic bank has paid or presented to a non-bank drawee for payment? ($103 34).
12. Does the bank retain a copy of each item, including checks, drafts or transfer of credit, of more than $10.000, received directly, and not through a domestic financial institution, from a bank, broker, or dealer in foreign exchange outside the United States? (§103 34)
13. Does the bank retain a record (letter of transmittal, cash letter, etc.) or each receipt of currency, checks, etc. and transfer of funds of more than $10.000 received from a bank, broker or dealer in foreign exchange from outside the United States? (103 34)
14. Does the bank, with respect to each account in a foreign country over which it has signature authority or in which it has financial interest retain records which show: (5103 24)
(a) the name in which the account is maintained:
fof the number or other designation of the account:
(c) the name and address of the foreign bank or other person with whom the account is maintained:
(d) the type of account; and
(e) the maximum value of the account during the reporting period?
15. Does the bank, with respect to each account in a foreign country over which it has signature authority or in which it has a financial interest report such relationship in accordance with the regulations? (¿103 241
*Unless otherwise indicated, the specified records that are created after June 30, 1972 must be retained for five years. (§103 36)
Officials Providing information to Examiner
The examiner should provide all details of apparent violations necessary for reporting to the Department of the Treasury.
Cc: Controllon of Curentercy District
SMSA• Stand And Metapolitano Statistical Areta ( for ex.
State INS GRANCE