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#1228037 - 08/06/09 12:52 PM CTR for cash for another bank
Anonymous
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We cash a large cashier's check on another local bank, brought in by the branch manager of that bank. CTR Part 1 is the manager's personal information. Do we need the other's bank information, or do we treat it strictly as an individual cashing a check?

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#1228044 - 08/06/09 12:57 PM Re: CTR for cash for another bank Anonymous
Skittles Offline
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Skittles
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TN
Was the cash for the bank's use? If so, a CTR is not required for another financial institution.
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#1228049 - 08/06/09 01:02 PM Re: CTR for cash for another bank Skittles
Anonymous
Unregistered

Yes it was for another bank's use. Does the amount matter--it was for over $50,000?

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#1228055 - 08/06/09 01:17 PM Re: CTR for cash for another bank Skittles
Kelsey D Offline
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Ohio
Originally Posted By: Duchess Skittles
Was the cash for the bank's use? If so, a CTR is not required for another financial institution.


A CTR is required unless you exempt them, which is very easy now that a DOEP is not required for them. While the initial DOEP and annual review are not a requirement, a bank still needs to take the same steps to verify the customer's initial eligibility for the exemption and document it.

If you decide not to exempt them, the CTR should be completed with the bank's information in section A and the manager's information in section B of Part I.
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#1228056 - 08/06/09 01:17 PM Re: CTR for cash for another bank Anonymous
Skittles Offline
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No, it doesn't matter the amount. All banks and government entities are exempt from CTR filings.
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#1228142 - 08/06/09 02:26 PM Re: CTR for cash for another bank Kelsey D
John Burnett Offline
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John Burnett
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Cape Cod
Originally Posted By: Kelsey D


A CTR is required unless you exempt them, which is very easy now that a DOEP is not required for them.


In reality, you don't exempt them. You verify that they are a bank and entitled to the exemption given to them in the regulation. All you have to once you've done that is add the bank to your exemption list so you don't have to go through the exercise again later.
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#1228210 - 08/06/09 03:13 PM Re: CTR for cash for another bank John Burnett
Kelsey D Offline
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Ohio
Originally Posted By: John Burnett
In reality, you don't exempt them. You verify that they are a bank and entitled to the exemption given to them in the regulation. All you have to once you've done that is add the bank to your exemption list so you don't have to go through the exercise again later.


I agree. You verify that they are a bank and add them to the list. My point was that you can't just go off the idea that all banks are exempt and so you don't have to file any CTR's. That's not the case. You may not have to go through a formal exemption process with a DOEP, but you still have to acknowledge that you've exempted them by adding them to the list. Unless you do that, you should file a CTR.
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#1228281 - 08/06/09 04:03 PM Re: CTR for cash for another bank Kelsey D
Skittles Offline
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TN
Actually, this was changed earlier this year and all banks are exempt along with all government entities. I learned this the other day in Ken Golliher's BSA training.
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#1228305 - 08/06/09 04:26 PM Re: CTR for cash for another bank Skittles
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
I'm aware of the change that took place in January, but are saying that there's no need verify that they're eligible, add them to your exempt persons list, and document it? You can simply just not file on them?
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Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1228421 - 08/06/09 05:26 PM Re: CTR for cash for another bank Skittles
Anonymous
Unregistered

So---No CTR necessary and no need to add them to an exempt list? That is also my opinion.

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#1228430 - 08/06/09 05:33 PM Re: CTR for cash for another bank Anonymous
rlcarey Online
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rlcarey
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Galveston, TX
You have to verify that they are eligible. Then add them to your exempt list and you are done.
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#1228434 - 08/06/09 05:35 PM Re: CTR for cash for another bank rlcarey
Kelsey D Offline
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Ohio
That's what I thought.
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#1228471 - 08/06/09 06:02 PM Re: CTR for cash for another bank Kelsey D
BrendaC Offline
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Sweet Home AL
Is there a requirement to have an exemption list?
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#1228498 - 08/06/09 06:15 PM Re: CTR for cash for another bank rlcarey
Anonymous
Unregistered

They are a community bank. What do I have to verify?

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#1228503 - 08/06/09 06:20 PM Re: CTR for cash for another bank BrendaC
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
"Is there a requirement to have an exemption list?"

You have to document compliance with the exemption rules.

31 CFR 103.22 (d)(5)(x) Documentation. The records maintained by a bank to document its compliance with and administration of the rules of this paragraph (d) shall be maintained in accordance with the provisions of 103.38.
Last edited by Kelsey D; 08/06/09 06:21 PM.
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#1230474 - 08/10/09 09:06 PM Re: CTR for cash for another bank Kelsey D
WonderWoman Offline
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gone fishin'
Anon - I typically print their page from the FDIC.
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