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#87432 - 06/11/03 07:46 PM BSA - CTRs
lisa Offline
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Joined: Aug 2001
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Gainesville, TX USA
Part II # 33 Currency Exchange(s)
Does that refer to a customer exchanging American cash for American cash or does it refer to exchanging foreign currency for American Currency?

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#87433 - 06/11/03 07:53 PM Re: BSA - CTRs
redsfan Offline
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The answer to your question is YES - it applies to both of those situations. Any time more than $10K in american currency crosses your counter, a CTR should be filed, no matter which direction the currency was moving when it crossed the counter.
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#87434 - 06/12/03 08:54 PM Re: BSA - CTRs
John Burnett Offline
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Let's clarify. Any time the cash equivalent of more than $10,000 US moves across your teller counter. . .

If you're an American bank and you exchange 20,000 Canadian dollars in currency for the equivalent in euros, (last I checked, 20,000 CD is more than $10,000 US), you file a CTR even though no US cash was involved.
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#87435 - 06/12/03 08:57 PM Re: BSA - CTRs
redsfan Offline
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John, I agree, with the exception that the amount should the equivalent of more than $10,000.

God created a few perfect heads, the rest he covered with hair. I salute another banker whose head grows closer to perfection daily!
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#87436 - 06/12/03 09:27 PM Re: BSA - CTRs
John Burnett Offline
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Absolutely correct, Paul. So I corrected my mangled English above to make that clear.

By the way, I think that I've been growing through my hair by pulling off and putting on all the hats we CO's a required to wear!
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#87437 - 06/12/03 09:40 PM Re: BSA - CTRs
Anonymous
Unregistered

A little more help in this area please!

Example: We take in 50,000 in Euro dollars (more than $10,000 US)and send for collection (no credit yet to the customer). Would we:

a) check block 29 Foreign Currency and enter the 50,000 Euro dollars as the amount the day sent for collection

b) wait for the exchange amount in US dollars and the actual deposit to their account (maybe 10 days later) then enter the US amount on the CTR

c)some other answer that I can't come up with right now

We don't handle a lot of foreign currency so we're a little puzzled on this one??

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#87438 - 06/12/03 09:42 PM Re: BSA - CTRs
Perplexed Offline
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SORRY! The previous question was from me. I have a bad habit of forgetting to login when I get in a hurry.
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#87439 - 06/12/03 09:52 PM Re: BSA - CTRs
John Burnett Offline
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We don't handle foreign currency collections much, either, but I'll take a shot at this.

First, you don't enter the amount in euros anywhere. All amounts on CTRs are in U.S. dollars only.

And you wouldn't treat this as a currency exchange, either, since you aren't pushing any cash over the counter to the customer.

My guess is that you complete the CTR as a cash deposit for the amount in dollars that you realize from the collection of the euros, and use the date the funds are credited to the customer's account as the transaction date. Result is only one CTR.

You also check item 29 and write in "EU" (for European Union, the issuer of the currency, not for "euro," the name of the currency).

The irony here is that your cash accounts probably won't see any of this transaction!
Last edited by John Burnett; 06/12/03 09:57 PM.
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#87440 - 06/12/03 10:05 PM Re: BSA - CTRs
Anonymous
Unregistered

Thank you, John. I appreciate your help.

That was what I told our teller to do but I wanted to be sure my thought process was correct. I think it was the point that nothing would reflect the cash transaction that had me second guessing myself. The credit to the customer's account will result from a debit to the correspondent bank account not a "cash in" debit as you mentioned.

Thanks again!

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