Business customer comes in on 3/9/11 to make large deposit. Breaks deposit out over two tellers. One teller gets deposit in on current day's business, amount $7,435. Other teller does not get deposit in until after cut-off, amount $6,315, shows up on 3/10/11 business day. Is a CTR required for the total $13,750? I'm thinking it's a yes, since customer brought deposits in on same day (left them with tellers to be deposited). This seems like a no-brainer to me that a CTR is required...but want to make sure.

If this is the business as usual I would investigate for a possible SAR.

There is no suspicious activity on behalf of depositer. They brought in several deposits and split them amount 2 tellers and left the deposits with the tellers to be completed at any point during the day. Just a case where one teller got hers in on the current business day and the other didn't get hers in until after cut off.

I would certainly fle a CTR even though 1 of the tellers was remiss and did not post until after cut-off but would not file a SAR since the customer did nothing wrong or suspicious.

And on the CTR would you use the date the deposits were brought into the Bank as the date of transaction?

I am sorry, to question the prior answers, but I always learned it was the system cut-off date that you use. That is why banks that are open on the weekend, but do not post until Monday, add the transactions to the Monday Batch for CTR purposes.

I may be wrong, but this is what I was told many years ago.

I don't know about the CTR but the branch needs to make sure future deposits are being completed on the same banking day.

To BC78a: you are correct about the cut-off rule but in this case the customer brought the deposits at the same time and it was only because of the laxness of 1 of the tellers that 1 of the deposits was not posted until after cut-off. I would certainly file a CTR.

Sorry, miss-read the original post. If the delay was caused by the teller, there should be a CTR. If the customer brought the deposit in after cut-off, it should be carried over to the next business day