I'm wondering if/how other bank's are handling change orders for businesses with regards to CTR filing?

Business customer makes an $11,000 deposit in cash, then hands the teller $500 in cash for a change order. Do you include the change order on the CTR? if so, how? Also, internally do you have your tellers doing a cash in and cash out ticket to account for the transaction or are they simply exchanging the cash?

As you describe it, there were two separate debits to cash. One was a deposit. The other was one side of a currency exchange. As they were conducted at the same time with the same teller, the bank "knows" and aggregation is mandatory. The $11500 CTR would indicate a deposit was made by checking box 34 and an exchange took place by checking box 33. "Multiple transactions" would be checked at the top of the form.

Some banks fill out debits and credits for currency exchanges or post them to the teller machine. Some do not. My opinion is that there should be a record of any currency exchange above $XX (amount established by policy).

We have change order procedures for our business accounts that occur in two steps if cash is presented. We have a special ticket the customer prepares and signs showing the denomination(s) of the cash in and how they want it back. Then we run a credit to the customers account, with a special option that indicates it is a currency exchange (this appears on the customer's statement) and then run a withdrawal with the same option. The break-down of denominations is requested for two reasons: to watch for money laundering and because some customers are on account analysis and this helps with the number of straps and rolls they are requesting. We have our tellers prepare any CTR that might be required on the day after the "triggering" transaction to make sure we have included all activity for the previous business day. This procedure is for amounts over $100.

Our tellers use a "Change List" option in their teller system. This records the break-down of cash taken in and cash given out. The person who processes our CTRs looks at the teller system for all "Change Lists" recorded on that business day, and adds them to the CTR.