I need help settling a disagreement regarding whether or not the bank should file a CTR.

A customer requested to cash a check in excess of $10,000. The teller asked the customer if they were sure they wanted to be carrying that much in cash and offered to make a cashier's check for part of the money. The customer accepted the offer and took a small amount of cash.

We have one officer saying that we should file a CTR because we did the cashier's check instead of cash and since the customer originally requested cash.

We have another officer saying no CTR is required since the cash was not given out, but we may need to file a SAR.

We have another officer saying nothing is required.

Please help settle this disagreement.

Research the cashier's check to make sure it wasn't cashed the same business day by the customer at one of your offices. If so, they hit the over $10k trigger. If not, then no CTR is required.

I wouldn't consider this SARable if the teller suggested the cashier's check for safety reasons. Nothing suspicious about that.

I agree with BrendaC.

Thanks!

In regards to the CTR, I agree with BrendaC. However, it may be worthy of a SAR if the person was suspicious. That cannot be answered by us since we were not there and do not know the entire situation.

I agree with the above. No CTR but you would want to be sure it wasn't cashed at one of your other branch locations. CTR's are only filed for cash in or out aggregates that exceeds $10K.

I wouldn't feel that this is a SAR situation since the cashiers check was suggested by your branch personnel and it doesn't appear that the customer was trying to avoid reporting.