We are trying to more fully automate the system by which we file CTRs. Although we use the FinCENe-filing, we want to be able to pass an automatic feed from our core processor to avoid manual entry. I'd like to share an example of an issue we're having and get some input.

Person comes in and makes a deposit to a business account. The amount is not enough to trigger the mechanism by which the teller would be required to collect that person's information. The same or another person comes in later in the day and does deposit an amount that triggers collection of their information. So now we have two transactions that contribute to the CTR, but we only have information on one conductor. Is it 'acceptable' to file the CTR with the business as beneficiary, the conductor for whom we have all of the information and then the conductor for whom we would have to indicate 'unknown'? Currently this would get bounced back to the branch to see if they have more information on the first conductor, which adds a delay to being able to file the CTR.

In other situations we've had it where none of the transactions alone trigger conductor information collection, but in the aggregate goes over the $10,000.01. Is it 'acceptable' to have the total amount as attributable to an 'unknown' conductor? Again, we usually bounce this back to the branch to see if they can supply additional information.

There is no requirement that you aggregate. In the first scenario you describe, you can simply file the CTR with two Part I's, the business and the one conductor whom you identified. There is not a required to file a third Part I checking "unknown" for everyone.

For your second scenario, as long as all of the deposits were below $10,000.01, at least one was made in person, and you identified none of the conductors, you would check the "aggregated transactions" box to indicate why none of the conductors were identified. You would have one Part I for the business.

Thank you. If I may, I'd like to posit one more example. If the aggregate goes over $10,000.01 and we've identified only one of the conductors (let's say he deposited $5,000), would we have the following:

Beneficiary (business) for the total amount
Known conductor for $5,000
'Unknown' conductor, aggregated transactions, for the balance?

This would make it so much easier to automate the process.

Thanks again, Doug

Two part I's for business and one known conductor. You do NOT check aggregated transactions because you have identified one conductor. CTR FAQ #27 speaks to this situation.

27. When do you check the “Aggregated transactions” box (Item 24)?

Filers should check box 24e “Aggregated transactions” (along with any other box applicable in Item 24) only in the following circumstance: 1) the financial institution did not identify any of the individuals conducting the related transactions, 2) all of the transactions were below the reporting requirement, and 3) at least one of the aggregated transactions was a teller transaction. If the aggregated transactions being reported included only deposits made via a night depository, the financial institution would not check “Aggregated transactions” as none of the aggregated transactions were a teller transaction; instead, the financial institution would check Item 24 “Night Deposit.” A “teller transaction” would include, but would not be limited to: the deposit or withdrawal of currency by an individual at the teller window, an individual making a loan payment with currency at the teller window or, an individual exchanging currency at the teller window. The option “Aggregated transactions” is not the same as Item 3 “Multiple transactions,” which can involve transactions that are above the reporting requirement.

For example, if there were four $3,000 deposits made into ABC Restaurant’s business account in one business day, and the filing institution did not identify any of the individual transactors, and at least one of these deposits was made via a teller transaction, the filing institution would complete a Part I on ABC Restaurant checking Item 3 “Multiple transactions” and checking “Aggregated transactions” in Item 24.

However, if the filing institution identified the fourth individual transactor, as a result of knowing the transaction takes ABC Restaurant over the $10,000 threshold, then the filing institution would complete a Part I on ABC Restaurant checking Item 3 “Multiple transactions” and a separate Part I on the fourth individual transactor. The filing institution would NOT check “Aggregated transactions” in Item 24 due to the fact that it identified one of the transactors.

If there were four $3,000 deposits made into ABC Restaurant’s business account via any combination of Armored car (FI Contract), ATM, Mail Deposit or Shipment, or Night Deposit, i.e., without any of the deposits being made via a teller transaction, the Aggregated transactions box should not be checked. Instead, the other boxes in Item 24 should be checked to the extent that they are applicable.

FIN-92-2, example 3 indicates banks should go back and try to identify the other parties who conducted the transactions.

People's Bank is encouraged to make a reasonable effort to provide the information for items 4 through 15 on the CTR. Such efforts could include a search of the institution's records or a phone call to the department store to identify the persons that conducted the transactions.

However, it's not widely known and I've never seen a bank cited for the failure. It is possible that whoever set up your system might have been aware of it, hence the kickback to the branch.

It was me that set it up, not knowing that particular citation, but knowing that you were supposed to supply as much information as possible 'if you had it'. However, since we don't have the information in the system, and in most cases the tellers are not always able to recall who made the deposit, I think we'll go the route Brian has outlined.

So would I.