August 2009

To address the housing crisis, President Obama has announced a series of initiatives in to help American homeowners. The Making Home Affordable programs were designed to keep mortgage rates low and assist homeowners either refinance or modify their loans to more affordable terms, depending on their individual situation. The U.S. Government, lenders, loan servicers, investors and borrowers are sharing in the responsibility to get the economy and the housing market back on track.

Dear [ ]:

I am responding to your letters, dated March 20, 2008, and June 8, 2008, to the Financial Crimes Enforcement Network ("FinCEN"), in which you seek an administrative ruling on the treatment of certain deposits for Currency Transaction Report, FinCEN Form 104 ("CTR") purposes. Specifically, you seek a ruling on behalf of your client, [ ] (the "Bank") on a scenario involving unrelated companies contracting with an armored car to make deposits that collectively exceed $10,000 in currency at a bank.