Blog: Deposit Compliance

Safe deposit boxes generate modest revenue, occupy valuable space, and produce a disproportionate share of a bank's litigation. The reason is a single persistent misunderstanding: customers believe the bank is safeguarding their property, and the legal relationship is nothing of the kind.

The Legal Relationship

A safe deposit box is a lease of space, not a deposit and not a custody arrangement. The customer rents a compartment; the bank provides a secure

The Currency Transaction Report is the most mechanical filing in the BSA regime and, for that reason, the one institutions most often get quietly wrong. There is no judgment call about suspicion and no narrative to write — which means errors are almost always about aggregation, party identification, or exemptions that were never maintained.

This guide covers the filing rules precisely, then spends real time on exemptions, because that is where most institutions leave money and staff ...