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CTR Requirement for Spouses/Joint Account

Answered by: 
John Burnett
BOL Learning Connect

Question: 
I need to know in this scenario if a CTR is required for the husband? The wife and husband come into the bank. The wife conducts a deposit to her personal (individual) account of $8,000 in cash. Then she conducts a deposit into the joint account (with her and husband) for $2,600. In my mind a CTR only needs completed on the wife because the wife is benefiting and conducted the $10,600 deposit. The husband did not conduct either transaction and is only benefiting from $2,600. Is my thinking correct? If required, please explain why a CTR is needed for the husband. Also, if a CTR is needed for the husband, I would like for you to consider this same scenario but without the husband present for the $8,000 deposit to the wife's account. When he enters the bank to make a $2,600 deposit to the joint account and we tell him we need to complete a CTR, wouldn't we be breaching customer information to tell him it is because his wife made a large cash deposit to her personal account early in the day?
Answer: 

A CTR is required when a cash-in or cash-out transaction or transactions is/are completed on the same business day BY or ON BEHALF OF a person.

FinCEN has said in its FAQ on CTR filing that a deposit to a jointly-owned account is considered made on behalf of each of the joint owners. Therefore, the $2,600 deposit in your scenario was made on behalf of both husband (H) and wife (W).

W was the conductor of both transactions, which means that both deposits we completed BY her, and you have to aggregate the deposits to determine whether to file. Since the total of $10,600 a CTR is required.

When completing a CTR, you must provide information on each identified person conducting the transaction(s) and on each person on whose behalf the transaction(s) is/are completed. You will complete the CTR to report that W conducted the transaction and that it was completed on behalf of W and H. Both of them are identified.

First published on 12/08/2019

Filed under: 
Lending
Filed under lending as: 
BSA
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