If a customer makes a $4,000 deposit in the nightdrop and then an $8,000 deposit in person, for Part 1, Section B on the CTR - do you:

Mark the box "night drop" and "multiple transactions" and leave the rest blank?

or

Mark the box "night drop" and "multiple transactions" and complete the section with the information for the person making the in-person deposit?


I think the first one (leave it blank); auditor thinks the second one. I don't see anything to support my position other than the language on the form itself, so I am looking for some help here!

If you have the info, you provide it on the form. You mark the FIRST "multiple transactions" box (at the top of the form) but you don't need to mark the box in Section B if you know who completed both transactions. You would mark "night drop" and provide the ID of the individual making the $8k deposit.

If you got it, include it regardless of the circumstances. Otherwise, Admin Ruling 92-2 includes a couple pearls of wisdom:

Item 3c should be checked to indicate that identifying information is not provided because transactions were received through the night deposit box. If the tellers involved with the two face to face deposits remember who conducted the transactions, institution records can be checked for identifying information. If the records contain some of the information required by items 4 through 15, that information must be provided, and item 3d must be checked to indicate that some information is missing because multiple transactions are being reported and the information was not obtained at the time the transactions were conducted. Item 48a must indicate 4 transactions and item 48b must indicate 3 locations. The zip code of those locations would be provided in item 48c.


[Box numbers may be off as this was published in connection with a prior version of the CTR.]

Ok - I stand corrected. Even though the form says "check a box if Section B is left blank" we should really check boxes even if we complete Section B, if we know the information.

Thanks for the help! I need to amend about 100 CTRs.

The point is that you may not have completed section B if you don't know who made the night deposit. But suppose that BrendaC makes the in-person deposit, you collect all the information you need from her, and she tells you that she's the individual who made the night drop, too. In that case, you have all the information to complete Section B, and you would not check the multiple transaction or night deposit boxes in Section B (but would check multiple transactions in Item 1).

SkiDoo - I would never recommend not correcting CTR errors, but off the record I would probably not amend because I failed to check a box on the Section B line (with the possible exception of "conducted on own behalf"). I likely would amend to document the ID of transactors if known.

By the way, John, someone took my $12k and pretended to be me. Please return my money immediately. Uncle Sam wants it.

I am thoroughly confused. I am going to just check boxes and provide info until the examiners or FinCEN tells me to stop. They need to clarify this for "slow" people like me.

We have no idea who make the night drop. I suppose we could ask, but why have the checkbox on the form if we are supposed to ask? I know the bookkeeper comes in and makes the deposit in person (she may be the one doing the night drop too, I don't know), so from now on I am checking multiple transactions on top; night drop in B and filling in B with the bookkeepers' information. If that is wrong - I give up. (I already amended the CTRs.)

First, I agree with Brenda. I will make wholesale amendments of CTRs when 1) I think the error would affect the value of information to law enforcement or impair our ability to locate the underlying transaction(s) at a future date or 2) when somebody empowered to do so makes me do it.

Second, 92-2 which I should have linked rather than cherry picked provides additional guidance on multiple deposits:



Note the word "encouraged." It's not a synonym for "required." If a bank wants to raise its standards to the point where it does everything its encouraged to do then I would encourage it to begin with today's transactions not yesterday's.