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#60261 - 02/10/03 09:18 PM Currency Transaction Report CTR
Anonymous
Unregistered

I’m new in overseen the filling of CTRs. I would like your opinion in how is the correct way to report/fill out the CTR on following sample:

One individual John Bee conducts the transaction on behalf the following customers (Cash In):

Deposit for $24,000.00 to be deposited to ABC & Associates.
Deposit for $100.00 to the account of Mary Bee
Deposit for $100.00 to the account of Steven Bee
Deposit for $ 300.00 to the account of John Bee

Total of the aggregate deposit $24,600.00

Thanks for your kind attention.

Magie

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Operations Compliance
#60262 - 02/10/03 09:25 PM Re: Currency Transaction Report CTR
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
All four of the entities listed get a separate Section A listing. Only John will be listed in Section B. For Part II, list all account numbers affected by these transactions, and the aggregate total of the transactions.

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#60263 - 02/10/03 09:28 PM Re: Currency Transaction Report CTR
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Check boxes 1b. If you will have separate cash-ins for each deposit, check box 1c, also.

Complete Part I section A on the front listing John B's information. Then check box e in Section B to show that one of the transaction was on John's behalf.

Get two copies of page 2 of the CTR form. Complete a Section A for ABC & Associates, another Section A for Steven Bee and a third for Mary B.

Back to the front -- Part II, fill in $24,600 in item 26. Then check box 34 and box 35, and list all five account numbers in box 35. Put the business date in box 28.

Have someone check it out.

File it.
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John S. Burnett
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#60264 - 02/10/03 09:29 PM Re: Currency Transaction Report CTR
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
John Bee doesn't get listed in Section B since he's already listed in Section A.
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John S. Burnett
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#60265 - 02/10/03 09:35 PM Re: Currency Transaction Report CTR
JacF Offline

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Joined: Nov 2001
Posts: 6,719
PA
Good point, John. I knew that, too- it must be Monday

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#60266 - 02/11/03 01:59 PM Re: Currency Transaction Report CTR
Anonymous
Unregistered

Please forgive me, but it's early and I may have read this wrong, but shouldn't John Bee also be in Section B under the other Section A's, since he conducted the transaction on behalf of the others?

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#60267 - 02/11/03 02:40 PM Re: Currency Transaction Report CTR
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
One unwritten rule for completing a CTR: A person is never listed more than once.

John Bee, in my suggested method above, was described in Section A of Part I (he benefited from one of the transactions). There are multiple Section A listings to cover the four accounts into which cash was deposited.

But there is only one Section B completed, since there was only one person who transacted all five deposits. That Section B, right under the Section A on the front of the form, was completed with just the check mark in box "e" (conducted on own behalf).

You never list the same person in both Section A and Section B on a CTR.
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John S. Burnett
BankersOnline.com
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#60268 - 07/02/03 10:13 PM Re: Currency Transaction Report CTR
Anonymous
Unregistered

hAVE A CUSTOMER WANTING TO CASH A$12,000.00 CASHIER CHECK FROM OUR BANK. gAVE HIM 8,000. IN CASH AND 4000.00 DOLLAR
IN ANOTHER CASHIERS CHECK. SHOULD WE FILL A CTR? THANKS BW

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#60269 - 07/02/03 10:21 PM Re: Currency Transaction Report CTR
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
No. He didn't take >$10,000 in cash out. Therefore, no CTR.
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David Dickinson
http://www.bankerscompliance.com

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#60270 - 07/02/03 11:20 PM Re: Currency Transaction Report CTR
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Posting a Dr. or Cr. entry of more than $10,000 to your GL account called "Cash" is not what triggers a CTR. As David indicates, the only thing that matters is long green walking through the door.
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#60271 - 07/03/03 11:18 AM Re: Currency Transaction Report CTR
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
Did the customer change the transaction from $12,000 cash to $8,000 cash and a $4,000 cashier's check when the CTR was brought out? If so, you are required to file a SAR. If not, why did the transaction change? Was the branch short of cash?
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#60272 - 07/03/03 01:19 PM Re: Currency Transaction Report CTR
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Let's not read into the question more than is there. Perhaps the customer only wanted $8,000 cash. If that's the case, I don't think one should assume anything, and a SAR would not be called for.

As you suggest, Skittles, if the customer changed the transaction when the CTR was dragged out, that's a horse of a different color, as they say. Or at least they used to say when I was younger.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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