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Old Oct 22, 2013 | 5:40 pm
  #378  
sgideons
 
Join Date: May 2012
Location: New England
Programs: DL PM, HH Gold, the rest come and go
Posts: 313
Originally Posted by cashback
Im going to have to disagree with you on your interpretation of the document. It does says a SAR must be filed if a transaction is over 2K and suspicious.

Then it goes on to say "A transaction is suspicious and must be reported if the Agent knows, suspects or has reason to suspect that the transaction or transactions:

--Designed to evade the requirements of the Bank Secrecy Act, whether through structuring or other means."

"Unusual Activity Monitoring and Examples of Suspicious Activities

Some red flags of suspicious activity may be:

--A consumer conducts multiple bill payment transactions just below relevant thresholds.

--A consumer uses two or more locations or cashiers in the same day in order to break one transaction into smaller transactions and evade the BSA reporting or record keeping requirement.

--The customer returns to purchase additional products in a short period of time (same day, consecutive days, or multiple days in the same week). "

Transactions through MS have the appearance of structuring (although we are not bc WM registers can only split 4x). The transactions are definitely out of the ordinary from normal walmart customers (which makes WM employees suspicious). While none of what we do is illegal, having the feds investigate and question you about your transactions is something nobody wants, innocent or not.

I have done many BPs as well, and I can almost guarantee they have filed SARs. One of the WMs basically treats me like a criminal every time.
I don't think you're disagreeing with me at all. I'm saying the same thing you are: non-suspicious $2k bill pays do not automatically trigger any scrutiny (unlike $2,500 and $10k bill pays).

On the other hand, some $2K transactions are suspicious. The suspicious ones have to be reported using SAR (which while they're forbidden to "tell" you, you'll know if they collect additional information, since the information collection requirements are only triggered at the $2,500 level).

So there's the question of interpretation (if you bill pay on Monday and Friday is that "multiple days in the same week?" As Comrade Stalin said, it's not important who votes, it's important who counts) and application (are your cashiers actually well-trained in the reporting guidelines? Do they care enough to fill out an SAR? Will there be any repercussions if they don't? Mine are not and do not).
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