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#1941842 - 07/16/14 08:58 PM CTR
baseballfan Offline
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baseballfan
Joined: Aug 2003
Posts: 169
Midwest
Customer brings in $15,000 in cash, purchases 2 cashiers checks ($6,000 and $8,925), and gets $75 cash back. The CTR would be filed for $14,925 since the customer kept $75 of the money, correct?

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#1941844 - 07/16/14 09:04 PM Re: CTR baseballfan
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Did the customer hand over the while ball of wax (perhaps because it was in $100 bills) and get "change"? If so, I'd record a total of $15,000 cash in, $14925 on line 25d and $75 on 25e.

Two weeks ago, I would have agreed with you. I've been persuaded that FinCEN would do it to show all the cash changing hands, and that it makes sense.
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#1941847 - 07/16/14 09:06 PM Re: CTR John Burnett
baseballfan Offline
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baseballfan
Joined: Aug 2003
Posts: 169
Midwest
Yes, the customer handed the entire $15,000 over, then took the $75 (because it had to be exchanged for smaller bills).

Thanks for your response!

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#1945660 - 07/25/14 01:07 PM Re: CTR transaction amount baseballfan
baseballfan Offline
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baseballfan
Joined: Aug 2003
Posts: 169
Midwest
Would you also include the amount of currency exchanged (in this case the $75) on line 27e as well as 25e?

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#1945984 - 07/25/14 05:58 PM Re: CTR transaction amount baseballfan
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Uh, no. The cash paid out is not more than $10,000. You can't include it on a CTR.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1947786 - 07/31/14 03:23 PM Re: CTR transaction amount John Burnett
baseballfan Offline
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baseballfan
Joined: Aug 2003
Posts: 169
Midwest
Thank you. That makes perfect sense, I was getting myself confused!

One final question: Is it ok for the amounts on Part II to not match the amount listed on line 21? Example - Customer brings in $20,000 cash, purchases a cashiers check for $19,875.56, receives $124.44 in cash back. Should the CTR be completed as follows:

Line 21 - $20,000
Line 25d - $19,876
Line 25e - $125
Part II Total Cash In line - $20,001

Is this correct?

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