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#1961531 - 09/12/14 03:21 PM File CTR or not
Calmeida12 Offline
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Joined: Sep 2012
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A business customer hands $10,100 in cash to a teller. On the deposit slip, he only wants deposit $10,000 and takes the $100 in change. Would that trigger a CTR? Is it what he hands in or what was actually deposited? Thank you.

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#1961533 - 09/12/14 03:26 PM Re: File CTR or not Calmeida12
Midwest BSA Offline
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Joined: Sep 2014
Posts: 57
I would say yes. $10,000 cash in and then $100 change order. Because your teller is actually handling $10,100, which is over the CTR threshold.

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#1961536 - 09/12/14 03:28 PM Re: File CTR or not Calmeida12
Doug Hendrickson Offline
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Doug Hendrickson
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$10,100 crossed the counter from the customer to the teller. CTR should be filed. $10,000 deposit to account and $100 on one side of currency exchange.
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#1961537 - 09/12/14 03:28 PM Re: File CTR or not Calmeida12
Calmeida12 Offline
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Joined: Sep 2012
Posts: 249
That's what I thought too. Our core processor is telling us that since the actual deposit was only $10,000 and the remaining was a cash back to the customer, that it doesn't trigger it.

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#1961540 - 09/12/14 03:29 PM Re: File CTR or not Calmeida12
rlcarey Offline
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rlcarey
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Galveston, TX
Since when does a core processer know anything about compliance???
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#1961547 - 09/12/14 03:33 PM Re: File CTR or not Calmeida12
John Burnett Offline
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John Burnett
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Cape Cod
Ditto that^^^. And I wouldn't count on the core processor to back you up if you're cited for not filing based on the processor's advice.
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#1961551 - 09/12/14 03:38 PM Re: File CTR or not Doug Hendrickson
Doug Hendrickson Offline
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Doug Hendrickson
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Your core processor doesn't file CTRs, thank god, you do. It is CTR-able.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1961844 - 09/13/14 01:31 PM Re: File CTR or not Calmeida12
Pat Patriot Act Offline
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I feel like joining the chorus here. A $10,000 cash deposit with a $100 currency exchange: file the CTR.
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