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#1295487 - 11/30/09 05:41 PM CTR help
justfriendlyme Offline
Joined: Oct 2006
Posts: 54
wisconsin, USA
I am not sure how to complete a CTR for the following situation:

Customer Sue Jones makes an $8,000.00 cash deposit to her individually owned checking; at the same time her husband Joe Jones makes an $8,000.00 cash deposit to their joint account at another branch location.

For section A do I have 2 section A's one for Sue and one for Joe and then list they conducted on own behalf or because Sue was the only one technically benefitting from the reportable amount have her listed in section A and list Joe in section b and also mark conducted on own behalf? I am having a post thanksgiving brain freeze on this. Thank you

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#1295545 - 11/30/09 06:38 PM Re: CTR help justfriendlyme
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
Since Joe has no control of the funds deposited into Sue's account I would not list Joe. Sue has control of all funds deposited- $16,000. I would complete the Section A on Sue- check block e "conducted on own behalf" in the first Section B. Complete a second Section B identifying Joe as a conductor.
Check Block B "multiple persons" on line 1 and show both account numbers on line 35.

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#1295547 - 11/30/09 06:43 PM Re: CTR help justfriendlyme
Flair Offline
Junior Member
Joined: Jun 2009
Posts: 44
Just one section A, as Sue is the only one benefitting from cash over the threshold. (I would mark multiple transactions.)Joe and "conducted on own behalf" in section B. Also, both account numbers should be listed under 35.

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#1295551 - 11/30/09 06:47 PM Re: CTR help nemsi
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
I disagree. I'd list both Sue and Joe in section A, but I can't put my finger on any documentation to support that. Let me look for a minute...

I'd like to change my answer to, "I'm not sure, but these two are probably right." Here is a similar thread that I think supports their answers. I jumped the gun because I was thinking of a situation that I recently had in which "Sue" deposited $15,000 into an individual account and later $500 into a joint account with "Joe". The difference was that I had the same conductor for both transactions. You don't, so that may make the difference. I'm interested in what others think.
Last edited by Kelsey D; 11/30/09 07:18 PM.
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1296762 - 12/02/09 03:03 AM Re: CTR help Kelsey D
aaron.kennedy@co Offline
New Poster
Joined: Nov 2009
Posts: 10
classic example of do what yo think you can best explain

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