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Completing a CTR When Identity Unknown

Answered by: 
Richard Insley | Guru Emeritus

Question: 
We recently had a member come in and pay off her auto loan in cash, $10,500. She however had a non member with her who had the cash in her possession and handed it to the teller. When asked to produce ID for the large sum of cash she said that she did not want to. She would be the conductor but her identity is unknown. How should the CTR be filled out?
Answer: 

This is not a complete answer--just some thoughts about how to approach the question.

Isn’t the member the conductor? The member’s source of funds is a separate consideration and may, itself, be the subject of a report.

Let’s say the mystery woman is an employee of another financial institution and that other institution is taking your loan out. If you report your member as conductor of a cash-in transaction and the other institution reports your member as a conductor of a cash-out transaction, the CTR database will contain a clear accounting of what happened.

First published on BankersOnline.com 3/7/11

First published on 03/07/2011

Filed under: 
Security
Filed under security as: 
Auto
Employee
ID
IT

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