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#1994177 - 02/06/15 05:21 PM CTR for Joint Account and Cash Back
Compliance Lover Offline
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Joined: Aug 2008
Posts: 555
One joint accountholder makes a deposit with cash back. The cash back requires a CTR be filed. (The deposited amount was small). I know to choose negotiable instrument cashed and I'm OK with listing the account number on the CTR but since it's a joint account do I list the other accountholder as a beneficiary (on behalf of)? I started to, and it's how the system kicked it out, but we don't really know that they benefited from the cash back portion. The check being deposited was payable to the person who was present.

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#1994187 - 02/06/15 05:42 PM Re: CTR for Joint Account and Cash Back Compliance Lover
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
If it was a withdrawal Question 23 would say that you would not be required to include the joint account holder. This isn't even a withdrawal; as you say, it's a check cashed transaction.

If you and I had a joint account and you split a $22,000 check into a $10,000 deposit and a $12,000 cash back, I'd be the first to tell you that I did not benefit from the $12,000!
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#1994195 - 02/06/15 05:54 PM Re: CTR for Joint Account and Cash Back Elwood P. Dowd
Compliance Lover Offline
Platinum Poster
Joined: Aug 2008
Posts: 555
Exactly. If the system hadn't have kicked it out the way it did I wouldn't have thought about putting them both on there for this situation (and I know the "system" isn't perfect and usually unreliable). Thanks.

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