I have a member that brought in $6100 in cash and then used $4150 out of their account to make a corporate check. She did not want the $6100 going into her account, so the teller pulled out the $4015 in cash then did cash in of $10,115 to the corporate check.
I am thinking we would just need to do the Monetary Instrument Log instead of a CTR, correct? Since there was not over $10,000 in cash going in or out of the building.
Thoughts?
-K

Let me make sure I understand the facts. Customer A walks in with $6,100 in cash and doesn't deposit it. Customer A withdrew $4,015 in cash from their account. Customer A then purchased a MI with cash in excess of $10,000? If that's accurate, you do need to file a CTR.

ACB- That is all correct. I guess I am just stuck on the fact that the funds were only withdrawn to avoid depositing the other funds. If teller had followed procedures the $6100 would have gone into the account and it would have been a MIL instead of a CTR.

I don't think a CTR would be filed since the customer did not walk in with over $10,000 in cash.

Haha, great...

1 Yes CTR
1 No CTR

Anyone else want to weigh in and break the tie?

I think I can argue it either way, but am unsure what NCUA/FinCen would like to see in the situation...

No CTR. It really should have been a split transaction of the funds coming from cash and the account, and the cash was not in excess of $10,000.

How am I missing this? Customer came in with $6,100 in cash. Customer withdrew $4,015 in cash. Customer then purchased an MI with over $10,000 in actual cash. How it should have been processed is a procedural matter and is not related to the actuall reporting threhold.

I could be wrong, but I would get some more opinions prior to making a decision.

For what its worth, I agree with the no CTR. The cash brought in was $6100. The money from the Savings account does not aggregate to the cash. I see it like when a teller does a checking to savings transfer but instead of running it in a split, they run cash tickets instead. The money doesn't actually come out of the drawer ever. I am sure the teller in this case did not pull the $4,015 out of the drawer.

You could always call the FinCEN helpline and ask them.

I'm for no CTR also. The actual cash involved was $6,100. The remaining $4,015 was a wasn't taken out of the drawer and handed to the customer, then handed back to the teller by the customer.

If ACB's statement is accurate a CTR is required.

If the teller made up a debit to cash, but did not handle the second amount in cash then it's a false positive as far as your system is concerned and no CTR is required.

The teller did a Cash Out on the system, but no cash left the teller's drawer. The teller then did a Cash In for the full amount, $10,115 to a check.

So, it sounds like no CTR then. So we will go ahead and record a Monetary Instrument Log then.

Thanks everyone for the input!

That's exactly why I asked for clarification Ken. Based on the OP confirming my example, I recommended filing a CTR. However, it would appear based on the OP's most recent post that a CTR is not required.