Deposits on Behalf of Exempt & Non-exempt Customer
Answer by Randy Carey, BOL Guru Guru Bios
Question: We receive weekly deposits from three merchants, two of whom have exempt status. The individual making the deposits for these two customers also makes an additional deposit for a non-exempt customer. The dollar amount for the non-exempt is usually between $1,000 and $2,000 in cash. The question: Should a CTR be filed for the total three deposits, even though two of the customers are exempt, since one individual brings in the total deposits (exceeding $10,000 in cash) in one bag? The same applies for night depository; they place all three deposits on one bag.
Answer: The two exempt customers' deposits are exempt from reporting regardless of who brings them in. As long as the third merchant does not exceed $10,000, you have no reporting requirements.
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