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#1429116 - 08/13/10 06:40 PM CTR - one depositer, 2 entities, 1 is exempt
Burgess Offline
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Joined: Jan 2004
Posts: 1,621
So how does this work.
one lady deposits $6,000 or so each for two seperate entities during the same day.
one of the entities is a phase 2 exempt entity.

No CTR because she only deposited $6k on the non-exempt entity??
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#1429136 - 08/13/10 06:54 PM Re: CTR - one depositer, 2 entities, 1 is exempt Burgess
Doug Hendrickson Offline
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Doug Hendrickson
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That is correct; if you have filed an exemption for one of the entities then there is not CTR to file in either case (one exempted, the other not greater than 10,000).
Last edited by Doug Hendrickson; 08/13/10 06:57 PM.
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#1429214 - 08/13/10 07:38 PM Re: CTR - one depositer, 2 entities, 1 is exempt Doug Hendrickson
AuditorK Offline
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Joined: Feb 2003
Posts: 962
PA
Wait a minute...don't we have one person walking in to the bank on a single business day and conducting more than $10,000 - it just so happens to be on behalf of two different beneficiaries? Why wouldn't this be reportable?

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#1429220 - 08/13/10 07:44 PM Re: CTR - one depositer, 2 entities, 1 is exempt AuditorK
Skittles Online
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TN
Actually, when I was in Georgia the FDIC told us this would have been reportable for that very reason.
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#1429225 - 08/13/10 07:47 PM Re: CTR - one depositer, 2 entities, 1 is exempt Skittles
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
I was under the impression that you ignore the exempt transaction in situations like this. No CTR.
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#1429232 - 08/13/10 07:49 PM Re: CTR - one depositer, 2 entities, 1 is exempt AuditorK
Doug Hendrickson Offline
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Doug Hendrickson
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I believe that when a business account is exempted, qualified exempt transactions in that account are ignored for CTR purposes, as if they never occurred (to quote a leading guru).

Therefore, it doesn't matter that there was a transaction to another account at the same time, unless that specifc transaction met the CTR limits and was not also exempt.
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#1429500 - 08/16/10 03:17 PM Re: CTR - one depositer, 2 entities, 1 is exempt Doug Hendrickson
John Burnett Offline
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John Burnett
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Cape Cod
That's correct. If I walk into your bank with $50,000 cash and deposit $45,000 of it to the transaction account of an exempt business and $5,000 to my personal account, you only have to concern yourself with the $5,000 deposit for CTR purposes, and therefore would not file one.
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