Skip to content
BOL Conferences
Thread Options
#415397 - 08/29/05 03:05 PM CTR on my bank?
Pinkie CRCM Offline
Gold Star
Joined: Aug 2003
Posts: 399
KY
Here's one...we recently concluded our United Way campaign and had all branches, depts, etc, have their own "fundraiser". We raised around $8700 in cash (split the pot, bake sale, silent auctions, jean day, quarter for cussing, etc). The cash was deposited into a bank owned HR Event DDA account.

What if....

we went over $10,000? Would we file a CTR on ourselves? We can't really "exempt" ourselves, even though we are a financial institution? Just curious for thoughts?!?

Return to Top
BSA/AML/CIP/OFAC Forum
#415398 - 08/29/05 04:01 PM Re: CTR on my bank?
Anonymous
Unregistered

Financial Institutions are automotically exempt, at least for domestic operations, aren't they? Why would you have to file?

Return to Top
#415399 - 08/29/05 06:48 PM Re: CTR on my bank?
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
The definitions in 103.11 say

"the term ``transaction in currency'' shall mean a transaction involving the physical transfer of currency from one person to another ."

In your case the funds were in possession of the same person, the bank, both before and after the deposit.

Return to Top
#415400 - 08/29/05 07:44 PM Re: CTR on my bank?
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Pinkie -- You didn't raise all that cash in one day, did you?
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#415401 - 08/29/05 08:41 PM Re: CTR on my bank?
Pinkie CRCM Offline
Gold Star
Joined: Aug 2003
Posts: 399
KY
No, this was through the course of one week, with 26 different individual branch fund raisers, as well as about 10 individual operational departments within the bank. We had a proof key off between a proof operator vs. the COO. It was pledge $1 for each batch of proof the operator keyed to the COO's one batch. Of course, the Audit Dept challenged the COO for 100% accuracy. That one event alone raised $25O!!

Return to Top

Moderator:  Andy_Z