Ok, we recently held a security training and were given differnt scenarios to complete with the correct procedures on our own. A friend of mine was given a real tough one, well it is to the both of us anyway. Here is my scenario

John Smith purchases a CD for $5,000.00 with cash at the main office. Later that same buisness day his wife Jane makes a deoposit of $6,000.00 in cash to their joint account. She then cashes a foreign check in the amount of &750.00.

John is employed as a bouncer at the local pub
Jane is self-employed as a babysitter

Ok, now what is to be complete on a CTR if in fact one is to be completed???? Oi' these are confusing!

You have one CTR for $11,000 with two conductors and two beneficiaries. The $750 cash out has no effect on the reportability of the cash in. Cash ins and outs do not offset each other.

The cash-in transactions benefiting John total $11,000. So a CTR needs to be filed for that amount.

The cash-out transaction is a red herring. It doesn't matter in the scenario, except to illustrate that you don't add the $750 to the cash-in total, and you don't net it out, either. You ignore it.

The CTR should indicate in item #1 that multiple persons and multiple transactions are reported. List either John or Jane in Section A on the front of the form; list the other spouse on the reverse in a Section A entry. Check the "conducted on own behalf" box above Section B on the front.

Be certain to complete the employment information in the appropriate box. You can use "Club bouncer" and "babysitter."

The fact that Jane only benefited from one of the deposits is not going to be evident from the information on the CTR. That's just the way this one shakes out, and you should not try to explain it.

Thanks alot for the info.

I also have another scenario...these CTR's are gonna be the death of me!!!

Suzanne Jones, Secretary for John Adams, comes in with cash in the amount of $7,000.00 to be deposited into the account of John and Sandy Adams. Later on the same buisness day she comes and deposits $4,000.00 in cash to her own account.


John: Lawyer
Sandy : Homemaker
Suzanne: Secretary

Suzanne conducted > $10,000 in cash. Therefore, a CTR must be filed. Mark the "multiple transactions" box in #1. Complete Section A on Suzanne Jones and another Section A on John & Sandy Adams. On the first page, mark Section B as "conducted on own behalf."

Cash in = $11,000, mark the deposit/withdrawal box and list both accounts.

From my BSA/AML burden comment letter:

The CTR form and reporting threshold was developed over 30 years ago. At that point in time, $10,000 was a huge sum of money. Also, at that point in time, SQL database and computer technology was in its infancy. However, we still have that same threshold, and the same basic form with many parts and boxes to cover any number of anticipated scenarios. However, no matter how carefully the form is designed, it can still be difficult to properly fill out the boxes to fit an unusual situation. If the incorrect boxes are completed, the financial institution is at risk of a regulatory violation not because the institution does not intend to comply with the law, but because the CTR can be almost as complex to fill out as an individual tax return. Yet, this form must be completed thousands of times each day in financial institutions across the country.

Given the technology that exists today, it would be far simpler for banks to submit a monthly report of all deposit accounts that had an aggregate cash in and/or cash out of $10,000 for the month. The report can be a simple electronic file that consists of:
Account name
Account number
Taxpayer Identification Number
Account address
Total cash in
Total cash out