08/18/2024
When filing a CTR on a business deposit, do you include everyone on the account like you would a personal CTR or just the actual conductor?
04/14/2024
We have a client who deposited a reportable cash transaction into he and his wife's trust account. We know we have to file the CTR for both wife and husband (joint account) but do we have to include the trust as a beneficiary?
01/28/2024
We have a business customer whose deposit runners are refusing to provide their information for us to collect as conductors of cash transactions. These are typically smaller transactions, but we require a conductors information on all cash transactions over $1,000 for aggregation reporting purposes. They previously banked at a larger regional bank which did not require these runners to provide identifying information. Are we OK to make an exception for this business client unless it is a CTR reportable transaction?
07/23/2023
We have a non-banking client who received several checks from his deceased grandmother (our client) which total over $10K. He is traveling from KS to Fla to cash these checks. Our problem is that he doesn't have a Social Security Number. Can or should we cash the checks and create a CTR, or refuse him? He does have a DL. He lives off the grid....we will file a SAR for sure.
06/04/2023
Are banks required to exempt customers for CTR filing limits? I've worked for banks in the past that never exempted anyone. We just filed CTR's on large cash transactions. So in short is there a regulation stating that banks need to exempt customers, or why is it done?
05/07/2023
If a customer doesn't truly deposit or receive over $10,000 in cash, but a bank transaction error causes it to appear that they did, should a CTR be filed or should the transaction just be documented appropriately? Example: A customer withdraws $8,000 in cash. The teller inadvertently runs the transaction twice resulting in software showing a $16,000 total withdrawn.
11/14/2021
We have a CTR dilemma. A customer came in with $20,000 cash.
- The funds were first deposited into his account.
- He then wanted to purchase a cashier check for $7,000.
- He returned later the same day with an account number of a family member and wanted to transfer $18,000 using the cash deposit and preexisting funds from his account. He is not on the family member's account.
The reason stated was that they are in the process of buying a house and escrow wanted him to show the proof of funds in a statement which was the reason for the transfer. How would you complete the CTR in this situation: is there only one Part 1 (customer) or two Part 1 (customer and family member)? And the $7,000, would be under negotiable instrument and $13,000 under fund transfer?
We also plan on filing a SAR.
10/31/2021
We continue to collect information regarding deposits over $10,000.00 from our customers who have a CTR exemption. Is this necessary?
10/31/2021
How do I handle Part III of a CTR if part of the withdrawal was at a branch and the other part was through an ATM at another location? The total cash amount exceeded $10,000.00 in one day.
10/31/2021
We continue to collect information regarding deposits over $10,000.00 from our customers who have a CTR exemption. Is this necessary?