CTR on Funds Transfer

Question: We have a vending machine company who hires Brinks to pick up their coin. Brinks stores it in a vault belonging to the bank, and brings us the deposit ticket for our customer, and we debit the vault and credit the customer, so the transaction here is by transfer of funds. This past week the amount of the deposit was over $10,000. Should we file a CTR? And do you think we should go back and check the deposits for the past year and file CTRs if there were any others?

Answer: Yes, the bank should file CTRs on these transactions, since they are cash transactions that exceed $10,000 (even if entirely in coin; even if the cash if first transferred by armored car to a cash vault.) The armored car is acting as an agent of the bank in this circumstance, and it is the bank's responsibility to report that transaction - not the armored car service. You might want to check and see if your account is subject to exemption. I'd find that out first, before considering backfiling. And before you backfile, ask FinCEN or IRS if they think it's necessary. Do I need to add - document your answer?

Copyright © 2005 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 15, No. 7, 7/05