We have a business customer who cashes checks at their bar for local workers, then brings these checks into us for cash. Do we have to go through each one and see if they are drawn on us when filling out the CTR (when the amount of all the checks aggregated is over $10,000)? or can we just check the box for "Negotiable Instruments Cashed" and leave item 35 blank. He may bring in 50-100 checks at once.

You seem to have a bigger problem here, rachelchri. If this bar is cashing over $1000 in checks per day he may be considered to be an MSB and would need to register as such. Your bank then has the reponsibility of monitoring their activity closely for BSA purposes.

The $1,000 per day is also PER PERSON per day, not just more than $1,000 cashed.

(2) Check casher. A person engaged in the business of a check casher (other than a person who does not cash checks in an amount greater than $1,000 in currency or monetary or other instruments for any person on any day in one or more transactions).

But do you really want to review the endorsers on all of these checks to see if anyone got more than $1,000?

And also, why would you provide cash for third party items? That must be a heck of a relationship to put the bank in that much liability.

As implied, require your bar to deposit the checks and then write a check to fulfill their needs for cash. Your CTR problem goes away.

In addition, you simultaneously restore some reliability to their bookkeeping and the calculation of their true income tax liability. You are facilitating their keeping a lot of their business off the books. If they express annoyance at your change in procedures consider the accusation confirmed.

Thank you guys for all your input!!!