Funds Transfer Report (for buying MO at Post Office)
Jan 22, 2016, 12:32 pm
#17
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Posts: 3,072
Anybody who takes two seconds to read the quoted form can see that this reporting requirement applies only to cash purchases. Debit cards are not cash. They are debit cards.
In my opinion, it is possible that this postal employee is targeting you. He sees you come in regularly, knows you have money as a result, and now is attempting to deceive you into thinking you are required to reveal your personal information in an attempt to utilize it in an identity theft scheme. I would politely decline and if the employee pressures you, I would notify the employee that his attempt to steal your identity will not be successful and if he continues pressuring you, you will have no choice but to contact law enforcement and report him.
Cliffs:
debit cards are not cash
/thread
In my opinion, it is possible that this postal employee is targeting you. He sees you come in regularly, knows you have money as a result, and now is attempting to deceive you into thinking you are required to reveal your personal information in an attempt to utilize it in an identity theft scheme. I would politely decline and if the employee pressures you, I would notify the employee that his attempt to steal your identity will not be successful and if he continues pressuring you, you will have no choice but to contact law enforcement and report him.
Cliffs:
debit cards are not cash
/thread
Incidentally, I was in a post office recently to mail things and a guy came in wanting to buy about $5,000 in $1,000 money orders in cash. When the lady informed him of the form, he lost his mind, but after a lot of hemming and hawing, he came back and filled it out.
Jan 22, 2016, 12:46 pm
#18
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Whether OP fills out the form himself or some retail store pulls information from his DL and other purchase information and uses that to complete a SAR, it's all headed into the same series of databases.
The thing about the USPS employee ID theft thing is laughable. More likely he's targeting OP as an AML suspect.
The thing about the USPS employee ID theft thing is laughable. More likely he's targeting OP as an AML suspect.
Jan 22, 2016, 2:29 pm
#19
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Andyandy
Jan 22, 2016, 3:41 pm
#20
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Join Date: May 1998
Posts: 1,139
And yet the distinction is quite clear both on the form OP cited and in FinCEN regulations. There simply is no legal requirement for reporting of non-currency transactions to FinCEN or any other federal authority. Of course, you are correct that that doesn't stop CSRs from filling out (or asking you to fill out) whatever paperwork they want.
No, it's not. At least if he's using it properly. The FTR OP cited is used to meet FinCEN/BSA reporting requirements, which do not involve non-currency transactions. But I totally agree that pushback isn't going to improve things. There's considerably more leeway in filing SARs which provide for voluntary reporting of things that a CSR thinks just might be fishy: https://www.fincen.gov/forms/files/FinCEN%20SAR%20ElectronicFilingInstructions-%20Stand%20Alone%20doc.pdf
Well, yes and no. Could OP be convicted for violating FinCEN/BSA regs? Probably not if he's just buying MOs, paid for with PPDCs, that were purchased with his own credit card. At the end of the day, the law is what 9 judges say it is, not what a CSR or prosecutor thinks it is. But could an officious postman make OP's life really inconvenient for a while? Yes, undoubtedly so.
Andyandy
No, it's not. At least if he's using it properly. The FTR OP cited is used to meet FinCEN/BSA reporting requirements, which do not involve non-currency transactions. But I totally agree that pushback isn't going to improve things. There's considerably more leeway in filing SARs which provide for voluntary reporting of things that a CSR thinks just might be fishy: https://www.fincen.gov/forms/files/FinCEN%20SAR%20ElectronicFilingInstructions-%20Stand%20Alone%20doc.pdf
Well, yes and no. Could OP be convicted for violating FinCEN/BSA regs? Probably not if he's just buying MOs, paid for with PPDCs, that were purchased with his own credit card. At the end of the day, the law is what 9 judges say it is, not what a CSR or prosecutor thinks it is. But could an officious postman make OP's life really inconvenient for a while? Yes, undoubtedly so.
Andyandy
Would you really feel comfortable advising a place like WalMart, or a car dealer, that they do not need to maintain a daily monetary log for $3,000 transactions or file CTRs for transactions exceeding $10,000 involving debit cards? If you would, that is great and I respect your opinion. But I have read pretty definitive rules regarding cash, checks, and credit cards, especially for auto dealers. But nothing on debit cards or stored value cards. If I go to the bank and withdraw $11,000 of cash and buy a car with that cash, reporting occurs for the auto dealer. If I buy the car with a credit card for $11,000, I do not believe any reporting exists for the auto dealer because I have incurred a brand new $11,000 debt to the credit card company - not any different than if I borrowed that $11,000 from the auto dealer. The flow of funds for a debit card looks to me a lot closer to the guy that withdrew cash and handed it to the auto dealer. But I could see someone saying the debit card transaction is more like a check (no reporting) or a credit card - since the cash clearly came from a known bank account. $11,000 worth of stored value cards are an even harder call, though. Whoever programmed WalMart's computer erred in the direction of gathering more rather than less information when debit or stored value cards are used. Most of the screens will not let the clerk advance to the next screen if $3,000 or more is involved.
Jan 22, 2016, 4:11 pm
#21
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The problem is that "debit card" has come to mean two entirely different things. It used to be a convenience tied to a checking account; now it can mean any piece of essentially untraceable plastic bought for cash at a million different places.
Jan 22, 2016, 7:41 pm
#22
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Jan 22, 2016, 8:11 pm
#23
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Jan 22, 2016, 9:46 pm
#24
Join Date: Jul 2015
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The distinction between debit cards / stored value cards / cash is not quite as clear as you state, and a great number of places choose to do a daily monetary log for any debit or stored value card transaction of $3,000 or more. WalMart simply programmed there computers to require this information for debit card transactions of $3,000 or more, as all of us learned who earned US Airways and Alaska miles at WalMart using Bank of America debit cards - clearly they viewed it as a cash-equivalent transaction, presumably the deemed withdrawal of cash from the debit card followed by the deemed purchase of money orders with that cash. That does not mean they are also doing a SAR for the transaction, but it increases the likelihood that they might. The form he described is likely used in the preparation of the daily monetary log, and in my humble opinion, sort of threatening the employee would increase the likelihood of a SAR being filed. If you do not believe there is debate as to whether debit / stored value cards represent cash, you should consider the rules on carrying $10,000 or more across borders. It is the government's worst nightmare that drug dealers can load $1 million on stored value cards and put all the cards in a carry on. Although I realize that most stored value cards cannot be used overseas, I read in a government study on the subject that customs considered adding machines that can read the value of stored value cards when a person is searched. Sometimes the law is not what a literal reading says it is, but is instead what the government employee says it is.
Jan 22, 2016, 9:57 pm
#25
Join Date: Jul 2015
Posts: 164
Would you really feel comfortable advising a place like WalMart, or a car dealer, that they do not need to maintain a daily monetary log for $3,000 transactions or file CTRs for transactions exceeding $10,000 involving debit cards? If you would, that is great and I respect your opinion. But I have read pretty definitive rules regarding cash, checks, and credit cards, especially for auto dealers. But nothing on debit cards or stored value cards. If I go to the bank and withdraw $11,000 of cash and buy a car with that cash, reporting occurs for the auto dealer. If I buy the car with a credit card for $11,000, I do not believe any reporting exists for the auto dealer because I have incurred a brand new $11,000 debt to the credit card company - not any different than if I borrowed that $11,000 from the auto dealer. The flow of funds for a debit card looks to me a lot closer to the guy that withdrew cash and handed it to the auto dealer. But I could see someone saying the debit card transaction is more like a check (no reporting) or a credit card - since the cash clearly came from a known bank account. $11,000 worth of stored value cards are an even harder call, though. Whoever programmed WalMart's computer erred in the direction of gathering more rather than less information when debit or stored value cards are used. Most of the screens will not let the clerk advance to the next screen if $3,000 or more is involved.
https://www.irs.gov/Businesses/Small...Dealership-QAs
scroll down to middle of page:
A customer purchases a vehicle for $15,000 and pays for it with $9,000 in cash and puts the remaining $6,000 on a personal credit card. Should a Form 8300 be filed? Instead of a personal credit card, the customer pays the remaining $6,000 with his ATM or debit card. Is the ATM or debit card amount considered cash or a cash equivalent that makes the total amount received over $10,000 and thus reportable on Form 8300?
No Form 8300 is required.
Less than $10,000 in cash was received. A credit card is not cash.
The ATM or debit card works the same as a credit card in this instance. The only difference is that the account will be charged with a debit against existing funds in the customer's bank account instead of creating a debt to be repaid later.
An ATM or debit card transaction is not treated as cash for purpose of filing a Form 8300 ; therefore, since the amount received in cash or cash equivalents is less than $10,000, the transaction is not reportable.
Jan 22, 2016, 10:04 pm
#26
Join Date: Jul 2015
Posts: 164
FinCen definition of currency:
https://www.ffiec.gov/bsa_aml_infoba...FR1010_100.pdf
Page 587:
m) Currency. The coin and paper money of the United States or of any other country that is designated as legal tender and that circulates and is customarily used and accepted as a medium of exchange in the country of issuance.
https://www.ffiec.gov/bsa_aml_infoba...FR1010_100.pdf
Page 587:
m) Currency. The coin and paper money of the United States or of any other country that is designated as legal tender and that circulates and is customarily used and accepted as a medium of exchange in the country of issuance.
Jan 22, 2016, 10:19 pm
#28
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Jan 23, 2016, 5:43 am
#30
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As usual, YMMV. A contract PO this way spooked after one 500 PMO, while the main PO was not spooked after several visits of 1k a day. I use PMOs as a backup to WUMOs when my regulars have issues with MO printers. That said PMOs, MOs and WU transfers are big business over here where native English speakers are the minority and large cash transactions and money movements are so commonplace that FINCEN is only seeking details on million dollar and over all cash real estate deals. Bienvenidos a Miami! 