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#1316262 - 12/31/09 05:29 PM CTR ?
Denovo Co Offline
Gold Star
Joined: Jan 2005
Posts: 375
NM
Customer comes in and cashes check for $10K. At the same time and the for the same acount, gives a deposit of $200 in cash but only wants to deposit $180. He presents another deposit of $400 cash but only wants to deposit $380. Do we aggregate the cash back from the $10k cashed check with the additional $40 we gave back to him for the smaller deposits for a total out of $10,040 on the CTR?

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#1316419 - 12/31/09 08:19 PM Re: CTR ? Denovo Co
MoodyBlue Offline
100 Club
Joined: Jul 2006
Posts: 183
Below the Mason Dixon Line
I would aggregate the cash outs and report the CTR.

Does this person do this on a regular basis----if so it would be structuring.

I've actually had a head teller "advise" a customer to "structure" in order to not report.
Last edited by elvisfan; 12/31/09 08:23 PM.
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#1316425 - 12/31/09 08:22 PM Re: CTR ? MoodyBlue
Aggs Offline
Diamond Poster
Aggs
Joined: Nov 2009
Posts: 1,331
Hoosier Country
I would say yes simply because the customer walked out of the branch with $10,040 in cash and because the $40 was an actual transaction that was handled by a teller. So even though he brought in $600 cash, he got $40 cash back from that transaction (I assume he didn't have any $20 bills and this is why he made such odd transactions.) So he made 3 transactions which, put together, triggered the need for the CTR.
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#1316439 - 12/31/09 08:37 PM Re: CTR ? Aggs
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
Yes, you would file a CTR. The customer exceeded the reporting threshold.
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