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We have a customer who is refusing to enter a remitter for a cashier’s check. We believe that the customer should enter in a remitter, for BSA purposes. The customer is very upset and wants to leave the remitter line blank. Is there any regulation we can point to? – IBA Compliance Connection

IBA Compliance Connection

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We have a customer who is refusing to enter a remitter for a cashier’s check. We believe that the customer should enter in a remitter, for BSA purposes. The customer is very upset and wants to leave the remitter line blank. Is there any regulation we can point to?

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We are not aware of any law or regulation that requires a bank to identify a remitter on a cashier’s check. However, both the Illinois Currency Reporting Act and FinCEN regulations require banks to obtain and record certain information for cashier’s checks issued for $3,000 or more, including the identity of the purchaser. In keeping with the spirit of these requirements, we believe your bank has the discretion to maintain a policy requiring a remitter to be listed on a cashier’s check.

For resources related to our guidance, please see:

  • Uniform Commercial Code, 810 ILCS 5/3-103 (11) (“‘Remitter’ means a person that purchases an instrument from its issuer if the instrument is payable to an identified person other than the purchaser.”)
  • FinCEN Regulations, 31 CFR 1010.415 (Requires financial institutions to maintain records for cashier’s checks for $3,000 or more, including the name and other identifying information of the purchaser)
  • Illinois Currency Reporting Act, 205 ILCS 685/5 (Requires financial institutions to verify the identity of the purchaser of a cashier’s check for $3,000 or more)