Should bank fees (Cashier Check purchase fee of $6.00) paid by the customer in cash, be added to their current CTR? If so, would the bank be the benefactor and the customer the transactor?
A question came up during a recent audit in regards to how a CTR would be completed for a local Diocese. This particular Diocese has a few different churches using the same EIN. Our system recognizes large currency transactions that we compare to see if a CTR was completed.
My question is, would a CTR be filed on that specific church when deposits of cash are over $10k, or on the Diocese?
Can you use "student" for an occupation on a CTR?
A customer cashes a large check that results in a reportable CTR. My question is that the funds from the check are for Christmas bonuses for the
customer's employees. I have the customer as the conductor, but who will be the beneficiary? Can we list the business as the beneficiary?
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.