CTRs: Collecting Information Without the Customer
Question: What can we do when we don't have the information needed for a CTR and it isn't noticed until after the person (in this case a homemaker) has left the branch that there were several transactions, all under $10,000, but the total is over $10,000?
Answer: If the transactions were conducted on the homemaker's own behalf but each transaction was under $10,000, the bank should check Box 1(c) of the new CTR Form (FinCEN Form 104). The numbering of this section has not changed from the earlier form, by the way. This is an indication why some of the information on the CTR may not be available to the bank - i.e., it didn't see the entire amount of the currency transactions until after it aggregated them after the fact. By then, the customer is long gone and the underlying records may not be available at the bank. Of course, if those records are available, the bank must include on the CTR as much information as it can about that particular customer. If the multiple transactions were being transacted by the same homemaker but were being conducted on someone else's behalf, the bank should check Box 14(d). Again, that lets IRS DCC know that some of the otherwise required information may not be available because the person conducted two or more cash transactions during the same business day and the bank did not aggregate them until after the fact. Conclusion - if you check Box 1(c) or Box 14(d), that "lets IRS DCC know that some of the otherwise required information may not be available because the person conducted two or more cash transactions during the same business day and the bank did not aggregate them until after the fact."
Copyright © 2004 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 14, No. 2, 5/05
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