Customer phones his bank and requests the shipment of foreign coins that he has owned for several years under a company name. We are filling out Part I Section A of the CTR with the company name and Section B we are checking off Item B for Mail Deposit or Shipment. Question is: Do you fill out Section B with the customer's personal information even though we checked off the Shipment box or do we fill out the Section with as much information as possible in items 15-25?

I do not understand the fact situation you offer, but the transactions that are reportable are,

each deposit, withdrawal, exchange of currency or other payment or transfer

If a customer simply moved a coin collection intact from one financial institution to another, I don't see how any of those things took place.

Customer took delivery of the coins - we shipped them to his home. The face value of the coins was over $10,000 so a CTR was prepared. Hope this clarifies.

If they were his coins, there is no transaction that I can see.

Where were the coins stored? How did the bank get them to ship them? Where is his home? Why would the bank step into the middle of a transaction like this???

I was wondering the same thing myself....

If your bank held a coin collection in some sort of custodial or safekeeping arrangement that is out of the ordinary and it sounds somewhat foreign here. If all that happened is you turned custody of the coins back over to the customer by any method, there is nothing to report.

We sell coins and bars. Client has the option to have us store it for them in a custodial arrangement or have the coins delivered. Doesn't the requirement for filing "currency" tnx's over $10,000 include cash & coin? Or do these types of coins fall in a different bucket? We've always filed and never been questioned.

The fact that you sold the coins was not part of the your original scenario, so we assumed there was no change in ownership. IMHO, the time for filing a CTR would be the time at which ownership of the coins vested in the customer, which would have been when the original purchase was made. The transfer from custody, again IMHO, wasn't a change in ownership.

Anyone else want to weigh in on this unusual fact situation?

Ok but the purchase of the coins was not with cash - just to clarify further.

No cash - no CTR.

So if I understand correctly, customer writes a check that exceeds $10,000 to purchase the foreign currency (or in this case coins). I agree with John, the CTR should be filed on the day the customer's account is debited for the purchase and the coins became his, even if the bank was holding them in safekeeping on his behalf. Here's the instructions for how to handle foreign currency.


Foreign exchange rate. If foreign currency is a part of a
currency transaction that requires the completion of a
CTR, use the exchange rate in effect for the business day
of the transaction to compute the amount, in US dollars,
to enter in item 26/27. The source of the exchange rate that
is used will be determined by the reporting institution.

Items 26a and 27a. Foreign cash in/Foreign cash out. If
foreign currency is exchanged, enter the amount of foreign
currency (Do not convert to U.S. dollars) in items 26a and
27a. Report country of origin in item 29.

Item 29. Foreign Country. If items 26a and/or 27a are
completed indicating that foreign currency is involved,
check Item 29 and identify the country. If multiple foreign
currencies are involved, check box 36 and identify the
additional country(s) and/or currency(s) involved.

If the customer wrote you a check then use the "negotiable instrument cashed" Box 32. If they used an over the counter withdrawal slip, then Box 34 "Deposits/Withdrawals"

The coins are cash as calculated by their face value. If they are foreign, their value would be calculated in U.S. dollars, but still based upon their face value.

My opinion is also No Cash No CTR, but apparently we had legal counsel opine a while back and they said otherwise. Thank you all for your responses.

One other aspect of this question. Currency is the currency and coin accepted in commerce of the issuing country. The US has never done it, but other countries have adopted new currencies and dropped old ones. Think of the deutchmark and euros in Germany. Money that is no longer accepted in commerce isn't currency for CTR purposes.