CTRs & Joint Accounts
Answer by David Dickinson, BOL Guru Guru Bios
Question: Is a CTR necessary if a husband and wife come in to the Credit Union together and each withdraws $10,000.00 from his/her own account and both are joint on each other’s accounts? Would a CTR need to be filed for the amount of $10,700 on a deposit of $700 to a personal joint account by one of the joint owners and then a deposit of $10,000 made later in the day to an LLP account with same owners (partners) but by the other partner? Later that day, an on-line transfer from the LLP was made to the personal joint account of $9000.
Answer: Typically, you only report the person conducting the withdrawal or others, if you have knowledge of anyone else benefiting from the transaction. For instance, if the husband says "My wife and I are headed to Vegas so I'm getting this cash". It sounds like they came at the same time and each withdrew $10,000 for a total of $20,000. I would list them both on a single CTR. I would also consider a SAR since it appears they were trying to get below the reporting threshold.
A CTR needs to be completed when one person conducts >$10,000 or receives >$10,000 in cash, since no one received >$10,000 and no one person conducted more than $10,000 in cash. Again, there may be structuring here to avoid the CTR reporting requirements, so a SAR may be warranted.
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