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#1606934 - 09/22/11 05:01 AM Re: Directors Fees Paid in Cash edAudit
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
When the bank makes a cash withdrawal like this, the funds don't change hands. The bank had the cash before the transaction; the bank (through its agent) still holds the cash after the transaction. That's why I would not file a CTR unless one or more of the directors gets more than $10K individually from the payout of fees.
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#1606957 - 09/22/11 01:09 PM Re: Directors Fees Paid in Cash smash
Polo Offline
100 Club
Polo
Joined: Feb 2003
Posts: 178
Not to beat a dead horse here... But, I agree with John B.
It has always been my understanding as this subject has been brought up in many BSA/AML seminars and resulted in the same general answer... "No CTR required". The main reason (I have heard) is that the bank employee is essentially acting as a teller. The employee is paying an obligation (not to another employee) generally, because few BOD members are acting as actual (payroll) employees, but an obligation (or bill) due.
Again, the payer (bank employee) is acting as a teller for the bank and simply disbursing funds. The bank would no more have to fill out a CTR for the transactions (unless a single person get more than $10M) than it would if a teller handled 10 separate transactions of $1,100.00 each in one day.
Our directors have been paid in cash for many years (long before my time) and our BSA examiners have always accepted this activity as separate non-reportable transactions.

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#1607030 - 09/22/11 02:21 PM Re: Directors Fees Paid in Cash edAudit
McGruff Offline
Gold Star
McGruff
Joined: Feb 2004
Posts: 262
Texas
Why pay in cash or even cut a check? Why aren't the payments ACHed into the directors' accounts? Get with the 21st century....

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