I don't think there is any guidance that speaks directly to this but here is my scenario:

Customer walks into the bank to make a payment for $10,075 in cash. They give you all $100 bills totaling $10,100 and you give the $25 in change back.

Do you report the $10,075 or $10,100? Essentially they are making a payment for $10,075 but they gave you $10,100. Do you consider giving the customer back his change as a “currency exchange”?

My take is you would file just the $10,075. I wouldn’t interpret the $25 in change as part of the transaction (or “currency exchange”)

How say you?

I would report it as cash in of $10,075 not $10,100.

In that situation described as above, I would report it as $10,100 cash in. That is how much came over the counter. Because the cash out was less than $10,000, the $25.00 would not be reported as cash out.





There are different examples on the detailed CTR -

http://www.fincen.gov/forms/files/fin104_ctr.pdf

I agree with working girl. If someone comes in with $10,100 in small bills and would like to exchange it for large bills. You report both the in and the out not $0.

The examples on the CTR doesn't really speak to my scenario because it is not technically a currency exchange.

I tend to agree with reporting only 10,075. Although the money came over the counter, it wasn't used in a transaction or in an exchange. In an extreme example... If I am a teller and a business customer handed me a bunch of $100 bills and said they needed to deposit $12,000 and he gave me $12,500, I would only report the $12,000 and hand him back his change/excess.

Thoughts?

F&M,

In your example, you are correct. However, the customer's intent was not to exchange money, just pay the loan.

I understand both sides of the coin. I am just looking for consistancy and to see if anyone has been commented on by an examinar in this situation.

What does the tellers cash in ticket say? That is what would get reported.

This is not the same scenario but it had me thinking about my original response.

Fincen FAQ:

Question 14: Is a CTR required when a person presents a check, in excess of $10,000, for payment in cash at a financial institution and receives less than $10,000 after fees, or other deductions, are charged against the amount of the check?

Answer 14: Answer 14: The BSA only requires a CTR for a transaction in currency, such as a deposit, withdrawal, exchange or transfer of currency, in excess of $10,000. A transaction in currency involves the physical transfer of currency from one person to another. Accordingly, the transfer of currency below $10,000 would not trigger the CTR requirement, despite the amount of the check. For example, if a person cashed a check for $10,100 and received $9,990 after a service fee was charged against the amount of the check, the financial institution would not be required to file a CTR. On the other hand, if a person purchased a cashiers check for $9,990 and paid a service fee of $20 for a total of $10,010 in cash, the financial institution would be required to file a CTR. The key lies in the amount of the physical deposit, withdrawal, exchange or transfer of currency. (10/2001)

Ok, I went and reviewed the CTR reporting instructions and I am changing my initial response. The CTR should report cash in 10,100 and $0 for cash out. Though it was not a "currency exchange" over 10,000 was transferred from one person to another.


Back of CTR Form:
Example 1: A person deposits $11,000 in currency to his savings account and withdraws $3,000 in currency from his checking account.

The CTR should be completed as follows:

Cash In $11,000 and no entry for Cash Out. This is because the $3,000 transaction does not meet the reporting threshold.

Whether it's more correct to report the cash in amount as $10,100 or as $10,075 is not a question I'd want to devote a lot of time to. To me, it makes more sense to have the amount in item 26 agree with the cash-in ticket for the transaction. Complicating the CTR by adding the cash-in half of a $25 currency exchange seems only to confuse matters.

I agree with John. The $25 seems to just complicate the matter.
I think the cash-out is confusing folks. It isn't a cash out transaction. I think in this example it is more about consistency. I will report the 10,075.

Thanks for the input everyone.

I'm on board with John as well. The cash in ticket should match the CTR.