On a CTR form, if the transaction is being completed by the owner of an entity do we check Person conducting transaction on own behalf in Part1,
Person Involved in Transaction?
How would I complete a CTR for an estate? The Trust Dept. opened deceased customer's safe deposit box and found $75,000 in cash. Funds were then
deposited into a trust fund. I know the trust employee will be the transactor but how do we handle the "on behalf of"? Do we just put customer's name even though he is deceased? There's no where to put "The Estate of ..."
We received a cash deposit exceeding $10,000 into a deceased person's estate account (personal checking). The executor is an authorized signor on the
account. Will the Benefactor for the transaction be the deceased? Will the executor be listed on the CTR as well? Note- the executor was not the
I am seeking some advise on BSA regulations around aggregation of secondary account holder. Is it a requirement by FinCEN to aggregate transactions based on secondary relationship between accounts and file a CTR?
Example: Joint account relationship
Account (A) - Chris (P) / Joe (S)
Account (B) - Joe (P) / Brian(S)
Chris as a conductor makes 6K Deposit into Act A at Branch X
Later, Joe as a conductor makes 5K Deposit into Act B at Branch Y
should a CTR be filed considering Joe has secondary relationship with Chris in Account A and ultimately benefits from the deposit made?
We need to do a CTR for an ITF account because the custodian came in and withdrew over $10K. For filing guidance we see examples of deposits, but not of withdrawals. Should the beneficiary of the trust be on the CTR assuming that funds withdrawn were for them? All we know is that the beneficiary walked out with the money. Also, should "ITF" be shown on the CTR anywhere?
Are savings account transactions considered exempt from CTR reporting for the business customer that is an exempt non-listed business? What about cash payments to a loan account?
From 31 CFR 1020.315: The exemptible accounts of a non-listed business or payroll customer include transaction accounts and money market deposit accounts.
From Federal Reserve Act 19(b)(1)(C): The term "transaction account" means a deposit or account on which the depositor or account holder is permitted to make withdrawals by negotiable or transferable instrument, payment orders of withdrawals, telephone transfers, or other similar items for the purpose of making payments or transfers to third persons or others. Such term includes demand deposits, negotiable order of withdrawal accounts, savings deposits subject to automatic transfers and share draft accounts.
A customer presents a cash deposit at the teller counter in the amount of $10,000. The teller counts the deposit and discovers it to be $100 over. The customer is made aware and requests the teller to give back the $100. Does this qualify for a CTR since it was handled by the teller while counting the large cash deposit or is it a simple mistake by the customer? We are also considering a SAR for possible structuring by the customer.
When filing a CTR on a business, and only one account signer made the deposit, is it required to get the information on the other signers that were not present to file the CTR?
We have a business that pays their employees by checks drawn off the same account. The employees sign the checks and gives them to the same person to cash the checks for them. The total of all the checks is >$10,000. The person bringing the checks into the bank to cash them, signs under the employee's name on all the checks.
How should the CTR be completed? Is she the conductor for all the employees or is it on her own behalf?
Is it proper to release a copy of a check for a CTR that was filed? The agent want to know the source of funds.