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.
If joint owners of an account make two separate withdrawals at different times of the day from the account which now totals over $10,000.00, is CTR required? Each individual withdrawal was less than $10,000.00.
We have recently discovered that a few CTRs were filed with a (1) transposed number on the customer's drivers license (teller error). We have corrected the issue and were not sure if we should amend the CTRs that were filed with a number off, or consider this information "not-critical" and proceed by filing with the corrected number from now on?ken
At what point would a CTR be filed for a Reg E dispute claim which states that over $10,000 in cash was deposited in the ATM? At the time a provisional credit is posted to the customer's account or at the time the Bank decides to make the provisional credit permanent, which could be 45 days? What business date is then used for the CTR, date of deposit in the ATM, provisional credit date, or permanency decision date?
When completing a CTR for a withdrawal by a grantor from a deposit account owned by a revocable trust (under same grantor's social security number), are two separate Part Is required? Both conductor and entity on whose behalf transactions was conducted (trust) both have the same social security number.
I have read several scenarios on currency in a deceased person's safe deposit box. We have one that I am not sure will meet the definition of "transaction" Case is single renter deceased, box drilled upon non-payment of rent. $18,000 in currency was in the box, that along with other items was verified under dual control and put into safe keeping. Later, staff started tracking down the estate or likely survivor. We found his spouse, and she had no idea he had the box. Upon proper documentation of her right to have box contents, she was given the currency, and no one at the branch considered that a CTR might be required. Since the dollar amount was never placed in a bank account of any kind, there was no transaction that the CTR software could see, so it did not appear there, or in BSA AML monitoring software. It is well past time to file. Do we need to start a back-filing request to FinCEN?
Question about BSA exemption. Customer has two retail stores (same business). Each store has its own deposit account. Can we combine account activity for both CTR reporting and exemption consideration?