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#2004535 - 03/27/15 01:15 PM Multiple Cash Trans Funding MI Purchase Question
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
Scenario:

Customer makes a $5,000.00 cash deposit on day 1. Same customer comes back on day 2 and makes another $5,000.00 cash deposit to the same account, then immediately purchases a cashier's check for $10,000.00 with a withdrawal ticket from the account. It's pretty evident that both days' deposits were to fund the purchase of the cashier's check. (A SAR investigation for apparent structuring has already been opened.)

I know I need an MI log entry for the cash purchase on Day 2. My question is should I include the Day 1 deposit on my log entry or do I only look at the cash on the actual date of purchase for the MI log entry?
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#2004642 - 03/27/15 04:26 PM Re: Multiple Cash Trans Funding MI Purchase Question Dani York, CRCM
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
I think this can be done either way; .. so a note referencing the prior day's activity is fine.
All the information will be on the SAR.

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#2004654 - 03/27/15 04:42 PM Re: Multiple Cash Trans Funding MI Purchase Question Dani York, CRCM
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,418
Galveston, TX
Who was the check payable too and what was it used for?

Your recordkeeping requirements end with the $5,000 deposited on the same day. Anything else that you do would not be turned over if the MI records were requested.
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#2004668 - 03/27/15 05:12 PM Re: Multiple Cash Trans Funding MI Purchase Question Dani York, CRCM
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
The check was payable to a title company and I am assuming used for a real estate purchase. Still digging that up for my SAR determination on the structuring.

So, as far as record keeping, I would treat the MI purchase like a CTR, ie just look at each day separately.

Thanks.
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.

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