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#1544639 - 05/03/11 02:53 PM Aggregate CTRs from multiple locations
CompliKat Offline
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CompliKat
Joined: Dec 2009
Posts: 96
I'm curious how others address this issue: We have a cellular phone corp that makes deposits at multiple branches with multiple conductors (seven!). We do not use the CTR function on our teller platform to prompt collection of conductor information (various hurdles not yet overcome) We BSA e-file 200+ CTRs monthly. Our CTRs for this company are quite cumbersome, especially since the conductors can change almost daily. Quite frankly it has become a pain in the tush to file these things. One peer at another institution indicated that he usually checked "multiple transactions" in section B and didn't report anything over two pages to the CTR. We file a CTR on this company daily, with at least seven conductors that can change frequently. How are some of you processing CTRs like this? I'm curious!

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#1544654 - 05/03/11 03:25 PM Re: Aggregate CTRs from multiple locations CompliKat
COComplyGal Offline
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Colorado
I know my bank does not have a situation this intensive however, I will say that on every single transaction over $10K, you need to identify the conductor. If you are collecting conductor information on all deposits just because you know the aggregate total is going to exceed $10K, I think you are going above and beyond.

Part of my brain is screaming, why do you have a cellular phone corp dealing with this much cash on a daily basis?!?! smile
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#1544663 - 05/03/11 03:40 PM Re: Aggregate CTRs from multiple locations COComplyGal
CompliKat Offline
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Very large cell co, with multiple store across the state...making deposits in several cities but all for the same corporate entity. And each deposit typically is under $10k but because they aggregate daily we collect the conductor info. Aargh....

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#1544673 - 05/03/11 03:48 PM Re: Aggregate CTRs from multiple locations CompliKat
Retread Offline
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Must be Metro PCS or something similar. They take nothing but cash for the phone service which is month to month and cash payment is required each month to maintain service. That's where all of the cash comes from.
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#1544675 - 05/03/11 03:49 PM Re: Aggregate CTRs from multiple locations CompliKat
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Have you thought about exempting them?

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#1544686 - 05/03/11 03:56 PM Re: Aggregate CTRs from multiple locations
CompliKat Offline
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Somewhere in the distant dark past... before I arrived... it was determined that we could not exempt a cell phone company. I have yet to locate anything that prohibits me from doing it and I really would like to because they are a burden. The activity is consistent, and while the cash makes up the bulk of their deposits they do quite a lot af check business too. This is probably "the" major cell provider in some of our communities so they do a whopping trade. I'm interested in any comments on exempting them too! But also still curious on how others handle the accregate CTRs...

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#1544688 - 05/03/11 03:58 PM Re: Aggregate CTRs from multiple locations
rlcarey Online
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Galveston, TX
I would think that if you are filing almost daily CTRs and are not collecting conductor information even if the transactions are under $10K, you are going to be cited for a weakness. While obtaining conductor information for transactions under $10K is not normally required unless the bank is aware of the CTR filing requirement at the time of the transaction, you are going to have a pretty weak argument under these circumstances.
Last edited by rlcarey; 05/03/11 03:59 PM.
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#1544724 - 05/03/11 04:22 PM Re: Aggregate CTRs from multiple locations rlcarey
CompliKat Offline
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That is why we have been collecting the information on all conductors, because we already know that we are going to tip the threshold. I recently got a bit of kickback from the branch that is tasked with the CTR prep. (As if I wasn't already aware that the CTR was burdensome!!!) I would like to make things easier for everyone but just don't see how it is possible. Hence the query to how others handle it...Has anyone out there exempted a cell company?

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#1544746 - 05/03/11 04:34 PM Re: Aggregate CTRs from multiple locations CompliKat
Georgia Plum
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Just do your due diligence on them. I've exempted MSBs and have had no backlash from examiners. My due diligence is documented. Are they big enough that they could be a Phase I exemption?

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#1544752 - 05/03/11 04:46 PM Re: Aggregate CTRs from multiple locations
devsfan Offline
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NYC
We had a similar situation, but with a seller of pre-paid phone cards, so exempting them was not an option in my opinion. If your customer is a cell carrier or agent you should look into exempting them. In our case, since going into the relationship it was known that there would be multiple deposits by multiple conductors I made it clear to the branch that all conductors must be identified and shown on the CTRs. As Randy indicated anything short of this in an account that you know will have a CTR almost every day would be a sign of a weakness. An alternative that we offered the customer was to have the salespersons deliver the deposits to the customer and then have the customer make the deposits. They could still make individual deposits for their bookeeping purposes if they wanted. The customer did not chose this option so the branch compiled a list of expected conductors with their identifying info so the CTRs could be prepared relatively easily. It was still a pain but the branch was willing to do the work since the balances were high.

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#1544832 - 05/03/11 06:30 PM Re: Aggregate CTRs from multiple locations devsfan
rlcarey Online
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Galveston, TX
CompliKat - If this is Metro PCS they are publicly traded and eligible for a Phase I exemption.
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#1545826 - 05/04/11 07:20 PM Re: Aggregate CTRs from multiple locations rlcarey
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Not Metro PCS. I am looking through things today to determine who the head of this monster is... It appears to be a subsidiary of one of the larger companies or some-such. I'm still digging. When I took this position I was told that they couldn't be exempted because of the type of business they are, but I'm not sure if that wasn't just a decision made out of an abundance of caution. Thanks

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#1545868 - 05/04/11 07:35 PM Re: Aggregate CTRs from multiple locations CompliKat
AMLKate Offline
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If you can review the customer and determine if they fit the exemption categories, then I would do so. However, I would make sure you have solid and thorough documentation of your CTR exemption review.

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#1545976 - 05/04/11 08:30 PM Re: Aggregate CTRs from multiple locations AMLKate
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OK, so I have determined that they "were" publically traded but are not at this time. It looks like they were acquired by another one of the big fish recently. They have rebranded their stores in the past couple months from "Blue" to "Red". Considering Phase II at this point. I do appreciate everyone's input... It sounds like we have been doing things right by including every conductor involved daily. If we do exempt them I know some branch staff that will be very happy!

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