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#1622107 - 10/31/11 04:10 PM CTR Question
netnbanker Offline
Joined: Nov 2010
Posts: 61
Quick question on a situation involving a CTR. Myself and a co-worker are in a bit of a disagreement. We had a customer come in and cash multiple checks. The checks were made out to 4 different people. We know this person and know that the checks are legitimate. However, the disagreement is this: Who is the actual beneficiary in this transaction? The person actually cashing the checks or the individuals for whom this customer is cashing them? Thanks in advance.

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#1622309 - 10/31/11 07:18 PM Re: CTR Question netnbanker
Rosebud123 Offline
Platinum Poster
Joined: Oct 2003
Posts: 645
I think that if the checks are made out to different people and there is nothing suspicious about this transaction, the beneficiaries are the four different people.

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#1622325 - 10/31/11 07:35 PM Re: CTR Question Rosebud123
3up3down Offline
Junior Member
Joined: Jun 2008
Posts: 25
We had a similar situation earlier this month. I contacted ABA and this is what they said,"If you are giving this person over $10,000 in cash, a CTR is required. It does not matter that he is cashing checks for other individuals or whether or not he directly benefits from the transaction. All you know is that this one person is walking out the door with more than $10,000: a CTR is required."

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#1622370 - 10/31/11 08:12 PM Re: CTR Question netnbanker
Cbecotte Offline
Joined: Jun 2009
Posts: 72
This may not be exactly the situation that you describe, but I think the premise is the same. This is directly from the FinCen website:

Question 13b: Would a CTR be required if several individual employees endorsed their respective payroll checks (all individual payroll checks are under $10,000 but combined they aggregate to an amount that exceeds $10,000), and made the checks payable to one employee who, in turn, cashed them at a financial institution for the purpose of distributing the proceeds back to the individual employees?

Answer 13b: A CTR would be required in this instance because one person is receiving more than $10,000 in currency.(10/2001)

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