To file or not to file: That is the question

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Question:

I have a customer who cashed a check for $10,880.00 and, after cashing, told the teller to make three separate deposits of $2000.00 each into three different accounts for which the memkber is a joint owner. Because the teller kept the cash and made the deposits do we have to file a CTR? I believe if we had given the money to the member and the member had given the teller back $6,000, a CTR would be required. But because the $10,880 was not handed to the member, the only cash transaction would be the net payout of $4,880 from the teller to the member, and a CTR would not be required.

Answer:

While you can certainly make a case for not filing a CTR based on the transaction as you described it, you should also consider how the credit union's cash account transactions reflect the transaction. If, for example, the teller generated a $10,880 cash-out to offset the check and three $2,000 cash-ins (or one $6,000 cash-in) for the deposits, the transaction will appear to include delivery of the full $10,880 to the CU member, in which case an auditor or examiner might expect to see a CTR filing.