CBT - Certified Bank Teller Teller Compliance and Regulations Questions and Answers — Questions and Answers
Question 1: A customer makes two separate cash deposits into their savings account in a single business day: one for $6,000 and another for $5,500. Under the Bank Secrecy Act (BSA), what action is the teller required to take?
- File a Suspicious Activity Report (SAR) because the transactions are structured to avoid reporting thresholds.
- File a Currency Transaction Report (CTR) because the total cash amount exceeds $10,000. (Correct answer)
- Inform the customer that they cannot deposit more than $10,000 in cash per day.
- Do nothing, as no single transaction was over $10,000.
Correct answer: File a Currency Transaction Report (CTR) because the total cash amount exceeds $10,000.
The Bank Secrecy Act (BSA) requires financial institutions to file a Currency Transaction Report (CTR) for currency transactions exceeding $10,000 in a single business day. This includes multiple transactions by the same person that aggregate to more than $10,000. In this scenario, the customer's total cash deposits for the day are $11,500, which triggers the CTR filing requirement.
Question 2: A teller suspects a customer is involved in illegal activities and is using the bank to launder money. The total amount of the suspicious transactions is $6,500. Which of the following is the most appropriate action for the teller?
- Refuse the transaction and close the customer's account immediately.
- Discuss the suspicion with the customer to get more information.
- File a Currency Transaction Report (CTR) due to the suspicious nature of the activity.
- Report the suspicious activity to their supervisor or BSA compliance officer to facilitate the filing of a Suspicious Activity Report (SAR). (Correct answer)
Correct answer: Report the suspicious activity to their supervisor or BSA compliance officer to facilitate the filing of a Suspicious Activity Report (SAR).
When a bank employee knows, suspects, or has reason to suspect that a transaction of $5,000 or more involves funds derived from illegal activity, a Suspicious Activity Report (SAR) must be filed. The teller's role is to identify and report this activity internally to the designated personnel (like a supervisor or BSA officer), who will then determine if a SAR should be filed with FinCEN. It is critical not to 'tip off' the customer that a SAR may be filed.
Question 3: According to Regulation CC (Expedited Funds Availability Act), which of the following deposits must generally be made available to the customer by the next business day?
- A $10,000 personal check from an out-of-state bank.
- A $7,000 cash deposit made at a non-proprietary ATM.
- A U.S. Treasury check for $5,000 deposited in person. (Correct answer)
- A personal check for $500 drawn on another local bank.
Correct answer: A U.S. Treasury check for $5,000 deposited in person.
Regulation CC specifies that certain types of deposits, considered low-risk, must be made available on the next business day after the day of deposit. These include cash, electronic payments, and government checks like U.S. Treasury checks. Personal checks and deposits at non-proprietary ATMs have different, typically longer, availability schedules.
Question 4: The Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions. What is a bank teller's primary responsibility regarding OFAC compliance?
- Advising customers on how to get their names removed from the OFAC list.
- Screening transactions and customers against the Specially Designated Nationals (SDN) list. (Correct answer)
- Reporting any foreign currency exchange transaction over $1,000 to OFAC.
- Issuing OFAC licenses for transactions with sanctioned countries.
Correct answer: Screening transactions and customers against the Specially Designated Nationals (SDN) list.
A bank's OFAC compliance program requires it to screen customers and transactions to ensure they are not doing business with individuals, entities, or countries on sanctions lists, most notably the Specially Designated Nationals (SDN) list. Tellers are on the frontline and play a role in this screening process, especially when opening accounts or conducting transactions for new or unfamiliar individuals.
Question 5: A customer reports that their debit card was stolen and used for an unauthorized $300 transaction yesterday. They notify the bank today. Under Regulation E (Electronic Fund Transfer Act), what is the customer's maximum liability?
- $0, because they reported it within two business days.
- $50. (Correct answer)
- $300, the full amount of the transaction.
- $500.
Correct answer: $50.
Regulation E limits a consumer's liability for unauthorized electronic fund transfers. If the customer notifies the bank within two business days of learning of the loss or theft of their access device (like a debit card), their maximum liability is limited to $50.
Question 6: Which of the following scenarios describes 'structuring,' an illegal activity that tellers must be trained to recognize?
- A business owner depositing a large amount of cash from weekend sales on a Monday morning.
- A customer exchanging a large amount of U.S. dollars for a foreign currency before an international trip.
- A customer making multiple cash deposits of $9,000 at different branches on the same day. (Correct answer)
- A customer wiring $15,000 to a family member in another country.
Correct answer: A customer making multiple cash deposits of $9,000 at different branches on the same day.
Structuring is the act of breaking down a single large cash transaction into multiple smaller ones to evade Bank Secrecy Act reporting requirements, specifically the filing of a Currency Transaction Report (CTR) for transactions over $10,000. Making multiple deposits below the $10,000 threshold at different locations on the same day is a classic example of this illegal activity.
CBT - Certified Bank Teller Teller Compliance and Regulations Questions and Answers
A customer makes two separate cash deposits into their savings account in a single business day: one for $6,000 and another for $5,500.
Under the Bank Secrecy Act (BSA), what action is the teller required to take?