Latest Compliance - Currency Transaction Reporting Topics

Cash Deposit At Teller Counter-CTR?

01/13/2019

A customer presents a cash deposit at the teller counter in the amount of $10,000. The teller counts the deposit and discovers it to be $100 over. The customer is made aware and requests the teller to give back the $100. Does this qualify for a CTR since it was handled by the teller while counting the large cash deposit or is it a simple mistake by the customer? We are also considering a SAR for possible structuring by the customer.

CTR Business- Only 1 Signer Made Deposit

12/30/2018

When filing a CTR on a business, and only one account signer made the deposit, is it required to get the information on the other signers that were not present to file the CTR?

Paying Employees by Checks Drawn Off Same Acct.

12/30/2018

We have a business that pays their employees by checks drawn off the same account. The employees sign the checks and gives them to the same person to cash the checks for them. The total of all the checks is >$10,000. The person bringing the checks into the bank to cash them, signs under the employee's name on all the checks. How should the CTR be completed? Is she the conductor for all the employees or is it on her own behalf?

Release Copy of Check for CTR that was Filed?

07/08/2018

Is it proper to release a copy of a check for a CTR that was filed? The agent want to know the source of funds.

Joint Owners Make Withdrawals Separately-CTR?

07/01/2018

If joint owners of an account make two separate withdrawals at different times of the day from the account which now totals over $10,000.00, is CTR required? Each individual withdrawal was less than $10,000.00.

CTRs Filed w/Transposed # On Drivers License

05/27/2018

We have recently discovered that a few CTRs were filed with a (1) transposed number on the customer's drivers license (teller error). We have corrected the issue and were not sure if we should amend the CTRs that were filed with a number off, or consider this information "not-critical" and proceed by filing with the corrected number from now on?ken

When to File CTR for Reg E Dispute Over $10,000

05/20/2018

At what point would a CTR be filed for a Reg E dispute claim which states that over $10,000 in cash was deposited in the ATM? At the time a provisional credit is posted to the customer's account or at the time the Bank decides to make the provisional credit permanent, which could be 45 days? What business date is then used for the CTR, date of deposit in the ATM, provisional credit date, or permanency decision date?

CTR for Withdrawal By A Grantor-Revocable Trust

02/25/2018

When completing a CTR for a withdrawal by a grantor from a deposit account owned by a revocable trust (under same grantor's social security number), are two separate Part Is required? Both conductor and entity on whose behalf transactions was conducted (trust) both have the same social security number.

Currency In Deceased Person's Safe Deposit Box

12/03/2017

I have read several scenarios on currency in a deceased person's safe deposit box. We have one that I am not sure will meet the definition of "transaction" Case is single renter deceased, box drilled upon non-payment of rent. $18,000 in currency was in the box, that along with other items was verified under dual control and put into safe keeping. Later, staff started tracking down the estate or likely survivor. We found his spouse, and she had no idea he had the box. Upon proper documentation of her right to have box contents, she was given the currency, and no one at the branch considered that a CTR might be required. Since the dollar amount was never placed in a bank account of any kind, there was no transaction that the CTR software could see, so it did not appear there, or in BSA AML monitoring software. It is well past time to file. Do we need to start a back-filing request to FinCEN?

BSA Exemption/CTR-Combine Acct. Activity?

12/03/2017

Question about BSA exemption. Customer has two retail stores (same business). Each store has its own deposit account. Can we combine account activity for both CTR reporting and exemption consideration?

Vendor Guru Q&A's - Compliance

Compliance tiers for Dodd-Frank Section 1071

Data privacy & Section 1071

Batch processing vs. transaction level processing for deposits automation

Section 1071

Exception management and better audits

Resolving credit and loan document exceptions

Proactive loan exception management

Tracking loan policy exceptions

Reasons for loan policy exceptions

Audits and document management

Authorized Signers and Corp. Accounts

01/26/2025

When opening a business account for a corporate entity, the authorized signers don’t necessarily have to be listed on the statement of information, is that correct? This would mean if the bank uses an internal corporate resolution form and it specifies the signers, and the form is signed by the corporate secretary, then the signers can be added, is that correct? Also, does the corporate secretary need to sign the EIN certification portion of the bank signature card, even if the corporate secretary isn’t one of the authorized signers?

Identifying a bank's branch locations

01/19/2025

Why Is it so difficult to ascertain whether or not an online bank has physical bank locations?

Recovering funds for a wire transfer fraud victim

01/19/2025

If wire transfers are made to what has been described as a legitimate business to the customer, is it valid that the customer is not able to have their money insured and get it back if the business is not legitimate and the customer is defrauded?

Reg CC and ATM Deposits

01/12/2025

How does Reg CC impact deposits made at ATMs, are there required notices or procedures and are they different for your own ATMs and others?

Is this a lottery or a sweepstakes?

01/05/2025

Our debit card vendor, TransFund, is doing a 50th Anniversary giveaway to its cardholders. In order for our cardholders to be eligible, we have to register our bank for the giveaway. If we do register our bank, every time our cardholders use their TransFund debit card for a qualifying purchase, they are automatically entered to win. TransFund will be awarding a $1,000 winner each month, qualifying them to win their choice of a new car, valued up to $50,000. In addition, TransFund will be giving away $500 per month to a qualifying cardholder who uses a TransFund ATM. TransFund is calling this a sweepstakes, but wouldn't this be considered a lottery? Can our bank register for this and then market it to our customers? I'm having a hard time understanding why a debit card vendor that does business with hundreds of banks in different states would put them at risk with the law by offering a lottery to its customers. I'm hoping my understanding of a lottery is just wrong. Any guidance you can give me, would be greatly appreciated.

Latest Compliance - Currency Transaction Reporting Topics

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