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#1946862 - 07/29/14 04:39 PM CTR Question
bankerdiva2 Offline
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Joined: May 2011
Posts: 110
Customer comes into the bank and withdraws $10,000 cash. He immediately walks outside to our ATM and withdraws another $500 cash. Then he goes to a competitor ATM and makes another $500 cash withdrawal. Do I complete CTR for $10,500 or $11,000? I know I want to do a SAR!!

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#1946866 - 07/29/14 04:44 PM Re: CTR Question bankerdiva2
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
If your records show that he withdrew the $500 from his account with you, regardless of the ATM used, it should be included. $11,000 is the total amount of cash he got from his account in one day, regardless of the ATM used.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1946867 - 07/29/14 04:44 PM Re: CTR Question bankerdiva2
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
IMO the CTR would be for the total withdrawn in cash from you and elsewhere; $11,000. SAR is also highly recommended, for structuring and stupidity.

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#1946868 - 07/29/14 04:48 PM Re: CTR Question devsfan
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
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Please don't suggest we file SARs for stupidity; I'd be here all day filing. grin

But I do agree on the structuring.
Last edited by Doug Hendrickson; 07/29/14 04:49 PM.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1946877 - 07/29/14 05:02 PM Re: CTR Question bankerdiva2
bankerdiva2 Offline
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Joined: May 2011
Posts: 110
Thank you! Yes, a CTR for $11,000 and a SAR for all cleverness this guys has...lol!!!

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#1947118 - 07/29/14 09:23 PM Re: CTR Question bankerdiva2
bankerdiva2 Offline
100 Club
Joined: May 2011
Posts: 110
I have one other question regarding this transaction. Would the ATM transactions be listed as "Withdrawals" (Line 27a) or "Other" (Line 27z). I have never run into a CTR that included ATM withdrawals, so thank you in advance for the assistance.

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#1947124 - 07/29/14 09:29 PM Re: CTR Question bankerdiva2
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
I believe the transactions would all fall under Withdrawals (Line 27a).
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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