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#1267570 - 10/15/09 08:34 PM CTR ?
Rae Offline
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Rae
Joined: Nov 2003
Posts: 192
I am sure I am just over thinking this but when a business has multiple checks cashed against their DDA account and the total Cash Out for the day exceeds $10,000.00 does that require a CTR? There are multiple persons cashing those items, some we know and others we don't. Help please......

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BSA/AML/CIP/OFAC Forum
#1267594 - 10/15/09 08:51 PM Re: CTR ? Rae
Sunshine_101 Offline
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Sunshine_101
Joined: May 2005
Posts: 127
Is one person benefiting from/recieving over $10,000 in cash in one day, if not, then the answer is no you do not have a CTR reportable transaction.
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#1267596 - 10/15/09 08:52 PM Re: CTR ? Rae
wgs0560 Offline
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Joined: Feb 2006
Posts: 6
Tennesse
Is the business receiving the proceeds of the cashed checks or are they payable to someone else? If the business is receiving the proceeds, then yes file a CTR - mark the box multiple transactions at the top and under section B. Try to get your staff to provide you with the info if they can

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#1267615 - 10/15/09 09:01 PM Re: CTR ? Rae
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
From the BSA FAQ's:

Question 13a: A business customer of a depository institution provides payroll checks to individual employees for work performed. Each payroll check is under $10,000. However, several employees cash their payroll checks individually on the same business day, which results in an aggregate cash out from the business customer’s account in an amount exceeding $10,000. Would the institution be required to file a CTR, if no one person received an amount in excess of $10,000?

Answer 13a: The financial institution would not need to file a CTR because it would not be involved in a single cash transaction (or multiple cash transactions for which a duty to aggregate would arise) of more than $10,000. A financial institution must treat multiple transactions in currency as a single transaction if the financial institution has knowledge that the multiple transactions are "by or on behalf of any person" and result in cash in or cash out totaling more than $10,000 during any one business day. According to the facts described above, the cashing of checks would be conducted by or on behalf of each individual employee (rather than the business on whose account each check is drawn), and no one employee would be cashing more than $10,000 in a single transaction or in multiple transactions during the same business day.
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#1267756 - 10/16/09 12:32 PM Re: CTR ? Rae
Rae Offline
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Rae
Joined: Nov 2003
Posts: 192
Thank you!

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