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#389393 - 07/21/05 09:05 PM CTR question
Becker Offline
Member
Joined: Dec 2002
Posts: 98
Iowa
Here's the situation: A business comes in and brings in $10,000 in large bills and receives smaller bills (to make change - not suspicious). Later same day a vendor comes in and cashes a check the business give them for $35 - putting cash outs of over $10,000. On the same day they also make a cash deposit of over $10,000. I guess this would be multiple transactions and would boxes 32, 34 be checked and then would you have to check box 36 and explain? Am I correct that the currency exchange box is only for foreign currency? This is a seasonal business and this does not and will not happen often, but we want to make sure we report it correctly. Thanks!

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#389394 - 07/21/05 09:13 PM Re: CTR question
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
When you say that "On the same day they also" do you refer to the business? If so you would include on the CTR the currency exchange and the deposit since that means that your customer came in with more than $10K during the day. You would exclude the check cashed by the vendor since it was he, and not your customer, that benefitted from that transaction. Currency exchange is not only for foreign currency.

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#389395 - 07/21/05 09:36 PM Re: CTR question
Becker Offline
Member
Joined: Dec 2002
Posts: 98
Iowa
The book I was reading stated that whenever Box 33 is checked, Box 29 had to be filled out. Perhaps this was for the old form or something. So, you're saying that I shoulc check box 33?

In answer to your question, Yes, I was referring to the business when I stated "on the same day they also".

I guess I was concerned because a report kicked out because more than $10,000 in cash came out of that account ($10,000 + $35) and usually that would trigger a report.

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#389396 - 07/22/05 01:20 AM Re: CTR question
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
If the $35 check was payable to and cashed by a vendor and the customer had earlier withdrawn $10,000 themselves - there would be no CTR required.
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#389397 - 07/22/05 11:59 AM Re: CTR question
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
Becker,

When you are reviewing your aggregation reports, keep in mind that the total cash-out figure may not be reportable depending on who the payees of the checks are. You only need to report cash-outs that benefitted the customer. Do not include checks cashed by vendors or payroll checks cashed by employees. Remember the general rule - "conducted by or on behalf of the same person."
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CRCM
Opinions expressed are my own.

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#389398 - 07/22/05 01:36 PM Re: CTR question
Becker Offline
Member
Joined: Dec 2002
Posts: 98
Iowa
Thank you!! That really does help. But I have one more stupid question. I would report the cash deposit (say it was $14,000) plus the exchange of bills ($10,000) for cash ins of $24,000, but I wouldn't record any cash outs because it was only $10,000. Do I have that right? AND (I lied -this is the second question). I should go ahead and check the currency exchange box and the deposit/withdrawal box? I'm sorry - I'm obviously making this harder than what it is. TGIF!

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#389399 - 07/22/05 02:00 PM Re: CTR question
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You've hit the nail on the head, Becker. You don't report any cash out figure and you do indicate that you're reporting both a currency exchange and a deposit.
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BankersOnline.com
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#389400 - 07/22/05 02:22 PM Re: CTR question
Becker Offline
Member
Joined: Dec 2002
Posts: 98
Iowa
Perfect - thank you! Sorry to be so dense about this, It must really frustrate you experts! I really do appreciate your help. You probably saved an amendment!!

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#389401 - 07/22/05 09:00 PM Re: CTR question
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Just remember, Becker. We were all there once. Sometimes it's just hard to remember when!
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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