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Completing CTR Correctly on Check Cashing

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Question: 
My question is on filling out a CTR. My bank has several business customers who cash checks for their customers. Due to this activity, several times a week they send in an employee with a check (ususally over $10,001) drawn on the business and made out to cash. The employee is the one who walks out with the cash and we assume that the employee is taking that money back to the business. Should we be filling out the CTR section A on the business (making the assumption that the business is benefitting) and put the employee in section B, or fill out the CTR section A on the person who comes in and actually receives the funds even though we think those funds are being used for the business to cash checks? Or even another scenario...filling out section A for both business and employee? Would it make a difference if there was a notation on the check stating "check cashing" or something we might use to know that the funds were going back to the company for use? Wehave debated all ways and wondered what the gurus thought.
Answer: 

Your instinct -- that the business is benefitting from the cashing of the check -- is on target. To feel better about that instinct, you can either ask the runner each time if the cash is for him/her or for the business, or you can suggest that the business annotate the check with its purpose and proceed accordingly.

Unless you believe the employee is benefitting from the cashing of the check (I'd bet he won't benefit from it more than once before losing his job and perhaps his freedom ), complete Section A about the business and Section B about the runner.

First published on BankersOnline.com 05/3/04

First published on 05/03/2004

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