Completing a CTR for Joint Account Deposits
Answer by Ken Golliher, BOL Guru Guru BIOS
Question: My CTR question is this: Husband makes a deposit to his individual account. Later the same day, wife makes a deposit to her joint account with the husband. Individually, neither transaction is reportable. Aggregated, they exceed $10,000 and the husband can benefit from the whole. Do we need to file a CTR and if we do, can you help us out with the technicalities? Do we check multiple persons, multiple transactions? And what do we do about the information we don't have on file (for example, driver's license numbers and occupations)? We caught this on a system report that monitors daily activity by social security number. Two different tellers were involved and had no knowledge on the day of activity.
Answer: Yes, the transactions must be aggregated if they are by or on behalf of the same person and the bank has knowledge of them. Deposits to a joint account are considered to be on behalf of each owner of that account. Here's a link to a September 1995 issuance from Treasury that addresses each of your questions in detail.
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