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#387435 - 07/18/05 08:55 PM CTR for cashing payroll checks
Anonymous
Unregistered

Would a CTR be required in the follo9wing circumstance:

Customer "A" has an account at Bank "B" which he uses for business purposes. He writes checks to his employees drawn on this account. Several of his employees cash the payroll checks at Bank "B", although they are not cusgtomers of Bank "B." (Bank B does this as a courtesy to their business customer.) The total of all the payroll checks cashed by Customer A's employees is over $10,000. Our systems aggreagtes this as cash out of customer A's account for CTR purposes. Is a CTR actually required?

Thanks.

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#387436 - 07/18/05 09:01 PM Re: CTR for cashing payroll checks
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
Not if the checks were cased by individual payees and no one person left the bank with excess of $10,000 in cash.
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#387437 - 07/18/05 09:08 PM Re: CTR for cashing payroll checks
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
A CTR is required only if a payee cashed more than $10K of checks for him/herself. You do not aggregate cash out at the account level since different persons received the benefit for the cash out.

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#387438 - 07/18/05 09:12 PM Re: CTR for cashing payroll checks
Anonymous
Unregistered

Nevermind, found answer at http://www.fincen.gov/reg_faqs.html...I guess I asked the question before fully researchig it myself (sorry)

answer is "NO"...

Question 13a: A business customer of a depository institution provides payroll checks to individual employees for work performed. Each payroll check is under $10,000. However, several employees cash their payroll checks individually on the same business day, which results in an aggregate cash out from the business customer’s account in an amount exceeding $10,000. Would the institution be required to file a CTR, if no one person received an amount in excess of $10,000?

Answer 13a: The financial institution would not need to file a CTR because it would not be involved in a single cash transaction (or multiple cash transactions for which a duty to aggregate would arise) of more than $10,000. A financial institution must treat multiple transactions in currency as a single transaction if the financial institution has knowledge that the multiple transactions are "by or on behalf of any person" and result in cash in or cash out totaling more than $10,000 during any one business day. According to the facts described above, the cashing of checks would be conducted by or on behalf of each individual employee (rather than the business on whose account each check is drawn), and no one employee would be cashing more than $10,000 in a single transaction or in multiple transactions during the same business day.

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#387439 - 07/18/05 09:16 PM Re: CTR for cashing payroll checks
Anonymous
Unregistered

Thank you for the quick responses skittles and devsfan...I guess your responses postwed as I was saying "nevermind"..thanks anyway!

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#387440 - 08/23/05 12:28 PM Re: CTR for cashing payroll checks
Anonymous
Unregistered

Has anyone set their cash out threshold higher than $0 to eliminate most payroll checks from their daily reports?

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#387441 - 08/23/05 04:10 PM Re: CTR for cashing payroll checks
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Set at $2,500.00

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