I have somewhat of a unique situation. My bank’s customer is going to be making a series of large cash deposits into an account opened at Chase. The account opened at Chase is in my bank’s name. Chase is taking the position that the CTR’s should be filed on my bank. When I pointed out that my bank is actually not benefitting from the transaction, the account rep seemed indifferent.

Am I mistaken in my assumption that our customer is benefitting from the transactions, thus they should be listed on Section A?

I didn’t even bother bring up a Phase I Exemption, because I don’t think she would have understood what I was talking about.

Any help would be greatly appreciated.

I'm sorry to say that I'm going to side with Chase on this one, because the account *is* in your bank's name.

In general, I can sympathize with the 'after 5PM on Friday' though. That's when all the really fun letters of credit pop up.

This is even though Chase knows that my bank is not benefitting from the transactions?

And if that is correct, why even file the CTRs? My bank could be granted a Phase I Exemption.

Why is your customer making cash deposits into your account at Chase?

This is a very big account. We expect a large volume of cash to be deposited into the account. More then what the operations department wants the tellers to handle. Also, we would prefer not to keep this amount of cash at our branch locations for security purposes.

So, we opened this account at Chase. The title on the account is "FI Name-Customer Name." However, Chase insists that the CTR must be filed on my FI. After the cash deposits are made, Chase will wire the funds to our customer's account at my FI.

Actually, a CTR needs to be filed on your customer. Whether you do it or Chase does it, it will be based on your contract with Chase. Just opening an account at a Chase branch is not the way to go on this......

That's what I thought Randy. Unfortunately, I don't think Chase is going to bend on this issue. Normally I would be surprised, but after the Wachovia incident, I'm really not.

So, I guess we are going to have to file the CTR's here.

We have a large cash customer who has his cash delivered directly to Fed. Fed credits our correspondent account, but we are responsible for doing the CTRs since ultimately the cash goes into our customers account. We also aggregate any other cash transactions made directly at our bank on the same day.

Had a similar situation at a previous institution. It was in our contract who was responsible for filling out the CTRs. We ended up exempting the customer ... so it was never an issue.

I don't know the size/make up of your bank, but when we've had special events where there is a lot of cash involved and didn't want it taken to a branch (or was occuring while the branch was closed), we've arrranged for an armored car to deliver the money right to our Central Cash Dept.