Ready, Set, In Compliance

The Federal Reserve Bank recently updated its Cash Services Operating Circular 2. This update applies to all retail and commercial banks. What does the new compliance information mean? Are you compliant? In this article, we’ll summarize the important changes so you can ensure your cash deposits are in compliance.

<b>Cash Deposits</b>
Under the new compliance, all currency deposits that use clear plastic bags must:

• Have a tamper-evident seal.
• Have a bag thickness of at least 5-mil.
• Be clear enough so that the contents may be easily seen.
• Not contain more than 16 bundles.

Bank notes must be bundled and marked according to the following criteria.

• A bundle consists of 1,000 notes of the same denomination in ten equal straps of 100 notes each.
• For note denominations $1s through $20s, a deposit must contain full bundles of 1,000 notes in 10 straps of the same denomination.
• For note denominations of $50s or $100s, a deposit can be made in the standard strap of 100 notes or in the full bundle.
• Each 100 notes must have only one strap around it.
• Straps must be color-coded, along with the edges, to conform to existing standards of the American Bankers Association (ABA).
• Use white rather than brown or beige straps to provide higher color contrast.
• Use a large and easy-to-read font on the stamp that you use to mark the currency straps.

<b>Coin Handling</b>
The new compliance measures also carry over to coin handling. Coin deposits may be made in either traditional standard canvas bags with seals or plastic bags.

If using plastic bags, they must meet the following requirements:

• Must possess a tamper-evident seal.
• Must be produced with a reinforced handle that is able to withstand a hang test with a 100+ lb. load.
• The plastic film that makes up the bag must have a minimum thickness of 6.5-mil to ensure the durability of the bag.
• The size must approximate that of the standard canvas bag.
• Contents must be clearly visible through the packaging material.
• Each bag must have a label on the opposite side of handle showing denomination, dollar amount, depositor’s name and the routing number.

If using canvas bags to make coin deposits, the bag must meet the following requirements:

• Each canvas bag must have a color-coded tag.
• The tag must contain denomination, dollar amount, depositor’s institution name and routing number.
• Coin must be sorted and bagged by denomination.

The Federal Reserve Bank may refuse a deposit if the integrity of a bag, plastic or canvas, appears to have been compromised or if a seal does not effectively deter access to the bag’s content.

Don’t wait to act until one of your deposits is rejected. These new compliance guidelines are simple to enact and may only require a small change in the types of plastic and canvas bags currently being used. Act today to ensure you meet the latest regulations of the Federal Reserve Bank.