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#1300405 - 12/07/09 09:13 PM Transactors on CTRs
Waterfall Offline
Member
Joined: Oct 2006
Posts: 96
PA
When 3 people come in on behalf of an entity to withdrawal money for the entity, we have been listing the entity as the beneficiary and the transactors as the 3 people. It is local farmer's market and we know the transactors are not the beneficiaries. It is not a multiple transaction since it is only 1 amount withdrawn. That means we have 3 part Bs and only 1 Part A.

I am sure that isn't correct, since we are to count the transactors as beneficiaries, but that is how my boss thinks we should file the CTR. Any help on how to handle this scenerio?

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#1300458 - 12/07/09 09:57 PM Re: Transactors on CTRs Waterfall
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
If you have knowledge that the transactors are not benefitting from this withdrawal, then your boss is correct. The entity that is benefitting goes in section A, and the three poeple making the withdrawal go in section B.
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1300464 - 12/07/09 09:59 PM Re: Transactors on CTRs Waterfall
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
i would list the one individual conducting the transaction in Section B. I'm assuming the other 2 came along as a security measure? that's my opinion.

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#1301469 - 12/09/09 01:18 PM Re: Transactors on CTRs nemsi
Waterfall Offline
Member
Joined: Oct 2006
Posts: 96
PA
Yes, they send 3 for security measures, but only one is at the teller window.

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#1301473 - 12/09/09 01:33 PM Re: Transactors on CTRs Waterfall
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
In that case, I agree with nemsi - just list the one who conducted the transaction.
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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