Aggregate the Transactions & File a CTR?
Answer by Randy Carey, BOL Guru Guru Bios
Question: This question is regarding BSA. We use Bankersonline Training. We currently have state examiners here and were told that if a customer deposited $7000 in cash today at one branch and then withdrew $4000 from the account at another branch on the same day that we need to aggregate the transactions and file a CTR for that customer. We say no, deposits and withdrawals are not aggregated. Who is correct?
Answer: You are. You aggregate all cash ins with all cash ins and all cash outs with all cash outs. If the ins or outs are over $10,000 then a CTR is in order. You do not add ins and outs together.
From FINCEN's Form 104 FAQ:
1. What should be entered in items 26 and 27?
If cash received totals over $10,000, enter the total amount of cash received in item 26 (“Total cash in”). If cash disbursed totals over $10,000, enter the total amount of cash disbursed in item 27 (“Total cash out”). Always enter the total dollar amount in items 26 and 27 using the U.S. dollar equivalent. If foreign currency is involved as part of the transaction, use the current business day’s exchange rate to determine the total amount in U.S. currency to enter.
“Cash-in” and “Cash-out” transactions should be considered separately, and not aggregated. However, they may be reported on a single CTR by using both items 26 and 27. (See example three and four in the CTR Instructions, or on the FinCEN web site).
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