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#1838484 - 08/01/13 03:34 PM CTR Night Drop- Unknown
BSA Lady Offline
100 Club
Joined: Jul 2012
Posts: 124
Example:

Business deposits through night drop 11k. On CTR form I know I will check "night drop" but do I also add a Part II and check person conducting transaction on another and click all "unknowns" OR is clicking night drop enough.

Thanks in advance.

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#1838496 - 08/01/13 03:46 PM Re: CTR Night Drop- Unknown BSA Lady
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Unlike the "aggregated transactions" check box, which is supposed to be used when all of the transactions reported are under the $10,000.01 trigger and you've therefore not identified any conductor, the "night depository" check box includes no such instructions. So, as dumb as it may seem, I think you have to include a Part II section will all the required fields checked as "Unknown."

Hint: If all of the transactions on the CTR are for $10,000 or less and you don't have information on any of the conductors, don't check "night depository" if one or more of them happens to have come in via that route. Just check the "aggregated" box.
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#1838518 - 08/01/13 04:03 PM Re: CTR Night Drop- Unknown BSA Lady
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
I'll go for the other side of the coin and say that checking "night deposit" is an adequate explanation for why you have no information on the person who conducted the transaction; it is unnecessary to check a series of "unknowns" if you, like Sergent Schultz, know nothing.

Either flip your own coin or use the Helpline as a tie breaker.
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#1838525 - 08/01/13 04:20 PM Re: CTR Night Drop- Unknown BSA Lady
TXBSA Offline
100 Club
Joined: May 2006
Posts: 171
TX
FinCEN had a Scenario like this on a webinar. This was the response:

Q: In the FinCEN CTR, when would I use the “Multiple Transactions” box and the “Aggregated Transactions” box?
Scenario II:
A bank receives two night deposits (each transaction below the reporting threshold) that totaled over $10,000 that are to be deposited into one business account.
The financial institution would file a CTR by completing a Part I on the entity to which the account, where the funds being deposited, belongs by selecting Item 2c (Person on whose behalf transaction was conducted) and Item 3 (Multiple Transactions). Additionally, the financial institution would select “Night Deposit” in Item 24 as no identifying information on the transactor was collected; “Aggregated Transactions” would not be selected in this scenario as none of the deposits was a teller transaction.

The slides for the webinar can be found at http://www.fincen.gov/whatsnew/pdf/CTR&DOEPRecordedVersion-PDFslides.pdf

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