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#1642053 - 12/21/11 09:33 PM Exempt Customers
CrashDavis Offline
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Joined: Jun 2005
Posts: 283
Our bank has several businesses(furniture mfg, nursing home facility etc) that has a payroll account with our bank along with other accounts. Their employees come to bank and cashes their payroll checks at our bank. We presently have not designated these businesses as exempt customers. Should they be on the exempt customer list as long as the total checks cashed by the employees exceed $10,000.00

Thanks

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#1642066 - 12/21/11 10:04 PM Re: Exempt Customers CrashDavis
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,718
Illinois
They should not be exempt based on this, nor should you be filing CTRs on this activity.

A CTR is only filed if an individual conducts or benefits from more than $10,000 in cash. In this most likely none of the employees have cashed a paycheck that exceeds $10,000, and the business does not benefit from employees cashing paychecks.
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#1642069 - 12/21/11 09:53 PM Re: Exempt Customers CrashDavis
CrashDavis Offline
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Joined: Jun 2005
Posts: 283
We are not filing CTRs because we understand that this doesn't meet the over $10,000 threshold.

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#1642209 - 12/22/11 02:24 PM Re: Exempt Customers CrashDavis
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
And, if you haven't had any CTR filings, the company isn't eligible for exemption.
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#1642238 - 12/22/11 03:07 PM Re: Exempt Customers CrashDavis
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
We are not filing CTRs because we understand that this doesn't meet the over $10,000 threshold.


Please review Brian C's post. You are not filing on these transactions because filing is not required even if they do exceed $10,000 on any given business day. Checks are cashed on behalf of the payee, not the drawer. Barring a circumstance where one person is cashing checks on behalf of several people, these are individual transactions and they are not subject to aggregation.
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