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CTR - BHC Tracking Deposits Across Bank Lines

Answered by: 
Barbara Hurst

Question: 
We are a 3 bank holding company. The question has come up regarding tracking deposit transactions across bank lines. For example: A customer of bank B goes to bank A and makes 3 cash deposits at 3 separate branches of bank A for $3,500; $3,500 and $4,500 during the same day. Our system does not track these 3 separate deposits for a CTR since individually they are under the $10,000 limit and the account is housed at bank B. Are we to be held responsible for this when our system doesn't track? If one deposit was over the $10,000 limit, we would be prompted to do a CTR?
Answer: 

If you go back far enough in FinCEN's instructions, you'll find that if you don't know about it, and can't determine it from your systems, you didn't have to report it. If I were you I'd go to FinCEN and get that from them in the form of an email or some other concrete writing. They will more than likely tell you that you would not be responsible for something you cannot track and have no knowledge of. But your examiner is something else. And when the examiner questions, you need to have some proof that you asked. FinCEN has been very cooperative, and they WILL answer questions like yours.

http://www.ncua.gov/GuidesManuals/examiners_guide/chapters/chapter19.pdf

First published on BankersOnline.com 10/17/2005

First published on 10/17/2005

Filed under: 
Security
Filed under security as: 
Branches
FinCEN
IT

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