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Information/Explanation of Aggregated Transactions

Question: 
Please explain aggregated transactions. I have a business and with three cash deposits all under the reporting limit. One transaction is done by a person and the other two are night deposits. Would I have to mark off aggregated on the CTR?
Answer: 

Patricia Cashman

There is a difference between "multiple" and "aggregated". "Multiple" is used when there is more than one cash transaction being reported regardless if one or all of the transactions exceeded the reporting threshold. "Aggregated" is used when there are multiple transactions, all of which were below the reporting threshold. This was originally a required field used to indicate why information on the "person conducting the transaction" was not obtained and recorded.

If the cash deposits were all made on the same "business day", then you would check both "multiple" and "aggregated". While "aggregated" is no longer a required field, it is quite helpful when you are explaining reported activity to an examiner or auditor or simply doing research.

Answer: 

Randy Carey

Pat - I don't understand this statement:

"While "aggregated" is no longer a required field, it is quite helpful when you are explaining reported activity to an examiner or auditor or simply doing research."

There are no "optional" fields on a CTR.

Answer: 

John Burnett

To clarify a bit: The "Aggregated transactions" box in item 24 is checked if both (a) each of the individual transactions being reported is for $10,000 or less; and (2) you are supplying no conductor (2b) information because you did not obtain it (because none of the transactions was reportable by itself).

Put another way, if you name one or more persons in your CTR and check box 2b for that individual, you should not select "Aggregated transactions."

Answer: 

Randy Carey

John,

Also one additional important requirement before checking the aggregated transactions box: "and requires at least one of the transactions to be a teller transaction."

First published on 09/01/2014

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