Skip to content
BOL Conferences
Thread Options
#1847319 - 08/29/13 05:54 PM CTR Transactor
Banker57 Offline
Gold Star
Joined: Jul 2010
Posts: 439
Minnesota
Scenario: John Smith deposits $7000 for ABC Company, the teller system prompts to obtain information. Later the same day Sally Jones deposits $4000 for ABC Company. This transaction then exceeds the aggregated CTR threshold. The teller system does not prompt for information. Is it required to have conductor information for both John and Sally or is Sally really the more inportant one as that is the transaction that meets the CTR filing requirements?

Return to Top
BSA/AML/CIP/OFAC Forum
#1847321 - 08/29/13 05:57 PM Re: CTR Transactor Banker57
CULady Offline
Gold Star
Joined: Sep 2007
Posts: 497
WA
You would need information for both. They both did a transaction that, together, added up to over $10,000. So one CTR with each of them listed as a "conductor."

Return to Top
#1847325 - 08/29/13 06:00 PM Re: CTR Transactor Banker57
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 85,384
Galveston, TX
Since both transactions individually are under $10,000, there is no regulatory requirement to have conductor information on either transactor on the CTR unless you have knowledge of who they were.

I find it very interesting that your teller system prompts for info on a $7,000 deposit but not when a customer exceeds $10,000. I have dealt with a lot of the typical teller systems and I would say you have something set wrong in your parameters.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1847334 - 08/29/13 06:05 PM Re: CTR Transactor Banker57
Banker57 Offline
Gold Star
Joined: Jul 2010
Posts: 439
Minnesota
If the teller system is set to prompt for information at say $5000, Sally's information is not obtained. What is the more important transaction/conductor to report, John's or Sally's as hers was the transaction the met the CTR threshold?

Return to Top
#1847341 - 08/29/13 06:09 PM Re: CTR Transactor Banker57
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 85,384
Galveston, TX
Neither is more important - you report what you know.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1847342 - 08/29/13 06:11 PM Re: CTR Transactor Banker57
Banker57 Offline
Gold Star
Joined: Jul 2010
Posts: 439
Minnesota
So you are saying that we set the prompt for $10,000. Any transaction that exceeds this amount, we collect information then. Even tho it could possibly be a small amount vs a very large previous transaction?

Return to Top
#1847345 - 08/29/13 06:15 PM Re: CTR Transactor Banker57
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 85,384
Galveston, TX
I'm saying, that if your policy is to gather information from individuals that conduct transactions over $5,000, then you report the individuals on which you have information.

Many teller systems prompt based on the amount associated with a specific account/customer regardless of the dollar amount involving a specific transactor.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z