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Question & Answer
Question: In a recent audit by our outside auditing firm the following CTR filing question was part of the questionnaire handed out randomly to our teller staff. We are now having a difference of opinion between our auditing firm and our compliance officer regarding the answer.
" Jeffrey Johnson, President of the Johnson Company, makes two cash deposits in one day: $27,000 to his business checking account (which is exempt for $20,000) and $9,000 to his personal checking account.
" What do we file? "
Answer: The answer is in Administrative Ruling 89-2, but we had to go to the Office of Financial Enforcement for a detailed explanation.
You should file one 4789.
The two transactions, AS LONG AS YOU HAVE KNOWLEDGE that they are by and/or for the same person, must be aggregated because the deposit into the company account exceeded the exemption.
Jeffrey Johnson will be in Part I as the transactor. Part II would be the "on behalf of" business, and on the reverse you would list the personal account number of Mr. Johnson.
But, please notice ... If the deposit had not exceeded the exempt amount on the Johnson Company account (for instance, if the deposit into the company account was $19,000 and the deposit into the personal account was $9,000) you would not have filed any CTR at all.
Copyright © 1993 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 4, No. 4, 9/93
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