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#1629475 - 11/17/11 12:01 AM Another CTR Question
pweiss Offline
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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?
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#1629486 - 11/17/11 03:43 AM Re: Another CTR Question pweiss
Y'all Comply Offline
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I would report it as cash in of $10,075 not $10,100.
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#1629490 - 11/17/11 12:04 PM Re: Another CTR Question Y'all Comply
Deputy Dawn Offline
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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.


Quote:

If there are both Cash In and Cash Out transactions that are
reportable, the amounts should be considered separately
and not aggregated. However, they may be reported on a
single CTR



There are different examples on the detailed CTR -

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

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#1629630 - 11/17/11 03:51 PM Re: Another CTR Question Deputy Dawn
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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.

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#1629636 - 11/17/11 03:59 PM Re: Another CTR Question Deputy Dawn
pweiss Offline
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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?
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Phil Weiss, CAMS

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#1629643 - 11/17/11 04:06 PM Re: Another CTR Question pweiss
pweiss Offline
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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.
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Phil Weiss, CAMS

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#1629658 - 11/17/11 04:18 PM Re: Another CTR Question pweiss
RSC Offline
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What does the tellers cash in ticket say? That is what would get reported.

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#1629668 - 11/17/11 04:30 PM Re: Another CTR Question RSC
Y'all Comply Offline
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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)
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#1629694 - 11/17/11 04:54 PM Re: Another CTR Question Y'all Comply
Y'all Comply Offline
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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.
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#1629807 - 11/17/11 06:33 PM Re: Another CTR Question Y'all Comply
John Burnett Offline
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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.
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#1629822 - 11/17/11 06:47 PM Re: Another CTR Question John Burnett
pweiss Offline
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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.
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Phil Weiss, CAMS

My opinions are my own and not that of my employer.

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#1629838 - 11/17/11 06:59 PM Re: Another CTR Question pweiss
ACBbank Offline
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I'm on board with John as well. The cash in ticket should match the CTR.
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