A customer brings in $12,000 in cash to pay $5,812.63 towards a loan and deposit the remaining $6,187.37 in cash to their account. On the new CTR form under item 25, it allows you to enter each amount for each transaction type, but it appears that you are supposed to round up each transaction type before you total the cash in amount. So, when you enter the rounded up amounts of $5,813 and $6,188 it totals to $12,001.

I am unable to find anything about this issue. Could someone direct me to any guidance on this? Should we round down in this split transaction scenario?

For banks, the Form 112 lists six different categorizations each for cash - in's (Item 25) and cash - out's (Item 27). In a specific situation, there could be an amount for each cash - in that ended in $.01. These fields do not allow for the entry of cents and the "General Instructions" are clear:

13. Monetary amounts: Record all U.S. Dollar amounts rounded up to the next whole dollar.

Thus, after you list each of the six amounts rounded up to the next dollar, the total on the CTR would overstate the actual amount of the transactions by $5.94. It's a discrepancy they are willing to tolerate.

Is there documentation anywhere that you are aware of that states the rounding issue is a discrepancy they are willing to tolerate? I have an FDIC auditor trying to cite it as a violation because the CTR reported the cash as $1.00 more than the actual transactions.

There is a previous thread on this somewhere. We actually had our software Vendor fix this issue to prevent overstating the amount.

The instructions should suffice for documentation. If your examiner is not literate, you should call the Helpline and offer to put the examiner on the phone when they call you back.

Since 1995 at least, banks have been reporting up to $.99 more than the aggregated transaction amounts. This is not really a recent development.

If you had four cash entries, each with a spare .25 at the end, yet you rounded down instead of up, then each of your four entries would be wrong.

Previous Thread

Thank you!

I don't mind being quoted or my posts used to back up a position, but the response I gave in the linked thread doesn't relate to the question in this thread.

Two issues: Rounding any fractional dollar amounts up in item 25 and its counterpart cash-out detail item will result in reporting a total that's inflated over the actual dollar total, and often more than would have been reported under the legacy CTR, on which you only reported the total (rounded up). That is what the directions call for, and one can assume without further corroboration that FinCEN, who designed the form and wrote the instructions, knows what's happening. That's the question posed in this thread.

In the other thread, my comment addressed the fact that the new form calls for dollar amounts in the "person" entries -- how many dollars of the reported cash-ins were on behalf of the person named; how many dollars were involved in the reported transactions conducted by this person; etc. Of course, if Ken deposits $15,000 cash to my account, you'll list the $15,000 amount on Ken's "conducted on another's behalf" page and on my "conducted on my behalf" page. There's no arithmetic relationship assumed between those pages (you don't add them together) since that would be counting the money twice.