Most Popular Compliance Content
CTR for an ITF Account-Filing Guidance
04/28/2019
We need to do a CTR for an ITF account because the custodian came in and withdrew over $10K. For filing guidance we see examples of deposits, but not of withdrawals. Should the beneficiary of the trust be on the CTR assuming that funds withdrawn were for them? All we know is that the beneficiary walked out with the money. Also, should "ITF" be shown on the CTR anywhere?
Acct. Set Up In Trust-Beneficiary Listed?
04/28/2019
Can an account that is set up in a trust have a beneficiary listed on the account?
Business Trust List Beneficiaries?
04/28/2019
Can a business trust list beneficiaries on the trust account? For example, another bank would like to set up a trust account with our bank and list their customers as the beneficiaries.
Adding to Time Acct. After Initial Funding
04/28/2019
Can we put a cap on how much may be added to a time account after the initial funding? For example, if a customer opens a time deposit with $5,000 and then wants to add $100,000, we would not allow that. Can we put a restriction in place that you could not add more to the account during the term than the original amount, so if the account was opened with $5,000 that they could not add more than an additional $5,000? Also can we allow an HSA CD to be a time account, or are there restrictions on this?
Exempt Non-Listed Business: Savings Acct. CTR
04/21/2019
Are savings account transactions considered exempt from CTR reporting for the business customer that is an exempt non-listed business? What about cash payments to a loan account? From 31 CFR 1020.315: The exemptible accounts of a non-listed business or payroll customer include transaction accounts and money market deposit accounts. From Federal Reserve Act 19(b)(1)(C): The term "transaction account" means a deposit or account on which the depositor or account holder is permitted to make withdrawals by negotiable or transferable instrument, payment orders of withdrawals, telephone transfers, or other similar items for the purpose of making payments or transfers to third persons or others. Such term includes demand deposits, negotiable order of withdrawal accounts, savings deposits subject to automatic transfers and share draft accounts.