Tellers have inquired about the application of the term 'multiple transactions' based on the following training scenario:

Customer withdraws $5000 from an account in currency, and receives cash and a receipt. Then the customer requests a currency exchange of $6000. Is the multiple transaction box 1c marked?

Clearly, if the customer leaves after the withdrawal & returns to conduct the exchange, the answer would be yes - does the same thinking apply if the customer doesn't leave between transactions?

My initial reaction is still yes, and we don't need a regulatory citation to tell us how to count to two - but after pondering for awhile, now I recognize that I'm thinking myself in circles. What do you do in your shops?

We would expect our tellers to check box 1c in this situation, too.

Bart,

The scenario you have described is two separate and distinct transactions requiring that 1c be marked. It makes no difference if they were conducted at the same time, a different time of the banking day, or for that matter at a different branch location. If you have knowledge that more than one transaction was conducted, then 1c needs to be marked. The problem that I periodically have with my tellers is when to use the "multiple transactions" under Section B.

And that can be confusing. Our understanding is that you check off the "multiple transactions" box in Section B if any of the multiple transactions being aggregated and reported on the CTR was separately conducted and $10,000 or less (so that complete information about the transacting party is not obtained).

For example, John Smith brings in a cash deposit to XYZ Inc. DDA for $9,500. Sam Jones brings in another cash deposit later to same account for $15,000. You report cash ins of $24,500, and put complete information about Sam Jones in Section B. You also complete Section B about John Smith, but you omit his ID because you never had an opportunity to obtain it. And that's why you check the multiple transactions box (because you have missing data).

Was the $6,000 currency exchange conducted with the $5,000 withdrawn or was it completely separate money brought in by the customer?

The training hypothetical assumed a $5,000 withdrawal from savings in cash; and a $6,000 exchange of Canadian for US. Total cash out was therefore $11,000 which the trainees were supposed to pick up on.

Tongue-in-cheek... if your hypothetical currency exchange was an exchange of $6,000 in Canadian currency into US currency, with the exchange rates being what they are, you probably didn't have a reportable transaction.

Tough crowd - it took less than an hour for someone to catch on to that. My tellers, meanwhile, have had this in their hands since the end of May, and no one has mentioned the exchange rate.

Maybe Euros is a better example for future training...

Or, Bart, you could clarify the example by saying the customer used $6,000 US to purchase the equivalent in Canadian funds. Then there's no question as to the exchange rate.