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#21189 - 06/19/02 01:57 PM CTR ?
Ms Auditor Offline
100 Club
Joined: Oct 2001
Posts: 148
Upstate NY
We have a new business customer that routinely deposits more than $10,000 in cash. Typically, the business will make 2 deposits at the night drop and will send a store manager into the bank to make a third. The aggregate of these 3 deposits is normally over $10,000. Do we need to identify the manager that comes into the bank and report this info on the CTR?

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Operations Compliance
#21190 - 06/19/02 02:23 PM Re: CTR ?
Anonymous
Unregistered

Since you have knowledge that the store manager is coming into the bank and conducting a same day transaction as those in the night drop, you are required to identify that individual on the CTR.

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#21191 - 06/20/02 01:19 PM Re: CTR ?
Javier V Offline
Junior Member
Javier V
Joined: May 2002
Posts: 40
I agree with Anon...If you have knowledge, file the CTR with the runner's info.

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#21192 - 06/21/02 02:28 PM Re: CTR ?
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Also, check box "c" in Section B to indicate that your Section B information is incomplete because one or more of the deposits was in the night chute.

Another possibility comes to mind -- If night bag 1 includes $5,000 in cash, night bag 2 includes $2,000 in cash, and store runner brings in deposit 3 with $6,000 in cash, it's possible that you won't know about the two night bags when processing deposit 3. At the time, you might not know the runner's ID, either. If your system aggregates the deposits overnight and you complete the CTR the next day for $13,000 cash in, you won't have any Section B information, and you'll want to check Section B box "d."

In the scenario described at the head of this string, the pattern always included a deposit by the store manager. In that case, as others have pointed out, you need to have info on the store manager in Section B (and box "c" checked off).
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John S. Burnett
BankersOnline.com
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