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#2263687 - 12/15/21 09:13 PM Transactor Threshold
terpsfan Offline
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We require tellers to ID the transactor on cash transactions $1500 and above for customers and noncustomers. The threshhold is set in the teller system and prompts the teller to request the information before completing the transaction. Once the teller enters the ID information into the system, it's saved. The next time that person does another cash transaction over $1500 the teller can do a search for their name, select the transactor's "profile" and complete the transaction without re-entering the info. Lately we have had several that we do not have a transactor for transactions included in a CTR due to the individual transaction being below this threshold. I assume most banks have a similar threshold. What do you do when you do not have transactor on these small transactions?

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#2263688 - 12/15/21 09:42 PM Re: Transactor Threshold terpsfan
BrianC Offline
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BrianC
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Illinois
In that case you don't include the unknown persons on the CTR.

In an extreme example, suppose you have 11 $1,000 cash transations all conducted by unknown individuals. Then you would check "aggregated transactions" in Part II to explain when you did not identify any of the individuals who conducted the transactions. Note in order to use "aggregated transactions" ALL of the following must be true.

1. All transactions are below $10,000
2. At least one transaction was conducted in person
3. The Bank did not identify ANY of the individuals who conducted transactions.

If you identify some individuals, but not all, you just file on those individuals you know and do not check aggregated transactions.
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#2263693 - 12/15/21 09:59 PM Re: Transactor Threshold terpsfan
terpsfan Offline
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Ok so there is no need to try and determine who the transactor was in these cases?

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#2263695 - 12/15/21 10:11 PM Re: Transactor Threshold terpsfan
BrianC Offline
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BrianC
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Illinois
No. The regulation only requires that you obtain information when you have knowledge that a CTR is required (such as when one individual brings in more than $10,000 at the same time.)
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#2263696 - 12/15/21 10:22 PM Re: Transactor Threshold terpsfan
Riece.F Offline
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Joined: Sep 2016
Posts: 23
Just curious, what teller software are you using?

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#2263703 - 12/16/21 02:21 PM Re: Transactor Threshold BrianC
John Burnett Offline
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John Burnett
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Cape Cod
Originally Posted by BrianC
No. The regulation only requires that you obtain information when you have knowledge that a CTR is required (such as when one individual brings in more than $10,000 at the same time.)
... or, for another example, you have a system that keeps track of cash transactions on behalf of customers during the business day and someone brings in a deposit for a business that brings that business's cash in total for the day over $10,000, and the teller is alerted to that fact. In this example, the teller should know to collect conductor information for the new transaction.
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