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#1668774 - 02/23/12 03:25 PM Another CTR Question
C.A.L. Offline
Junior Member
C.A.L.
Joined: Mar 2011
Posts: 34
Far Far Away
Here is the situation that I have...

Money Transfer Company has numerous agents that make several deposits at different locations in one day:
$660.00 (No info on conductor)
$10100.00 (Info on conductor)
$560.20 (No info on conductor)
$200.00 (No info on conductor)

Our transaction processor does not aggregate (we are workin on that), so the tellers do not know that the other transactions have been completed. That is way the only one that has conductor info is the one that is over $10,000.00

I was told by an examiner that I would need to include the one conductor I have in Section B, mark (d) Multiple Transactions in Section B and also mark (b) multiple person on Line Item 1. (since we know there was more than one person involved)

Now the Efile system will not allow this since there are not Multiple Section A's or Sections B's.

I have been filing these paper form and marking the Multipe Person box with a pen. I have not had any other examiners dispute this so I assume this is the correct way to file them. However before long I will not be able to file them paper form and I am in need of some advice on this.

Does anyone else have a situation like this? If so, how do you handle this type of transaction?

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#1668781 - 02/23/12 03:17 PM Re: Another CTR Question C.A.L.
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Based on the facts you presented, you don't actually know whether multiple persons were involved. Document the ID of the conductor you know and check multiple transactions (meaning that transactions under $10k were conducted which, when aggregated, triggered the CTR filing thresh hold). You did not have "knowledge" the thresh hold had been crossed when conducting the subsequent transactions; therefore, you were not required to document the conductors.
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#1669030 - 02/23/12 06:38 PM Re: Another CTR Question C.A.L.
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
We had a business customer with a similar pattern of multiple deposits by differrent conductors and my instructions were to ID every conductor since we could anticipate that there would be CTR-reportable deposits every day and I did not wish to file reports with incomplete information. I was not popular but so be it.

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#1669048 - 02/23/12 06:41 PM Re: Another CTR Question C.A.L.
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
It is a very common occurrence since most businesses will periodically drop cash to have less cash on hand in the business. While you may maintain manual deposit records for deposits under the reporting thresh hold, there is no requirement to do so.
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#1669072 - 02/23/12 07:12 PM Re: Another CTR Question C.A.L.
C.A.L. Offline
Junior Member
C.A.L.
Joined: Mar 2011
Posts: 34
Far Far Away
@ devsfan...I also had someone instruct me to id them all as well until we dicussed the 50+ pages that the CTR would contain. Then I was told to get as many as I could and still mark (b) multiple person on Line Item 1, but I have 20 transactions and only 1 conductor id'd then that posses a problem.

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#1669077 - 02/23/12 07:14 PM Re: Another CTR Question C.A.L.
C.A.L. Offline
Junior Member
C.A.L.
Joined: Mar 2011
Posts: 34
Far Far Away
@ BrendaC...thanks for the help. smile

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#1669156 - 02/23/12 08:23 PM Re: Another CTR Question C.A.L.
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
You are required to report what you "know". For any cash transaction over $10k. BSA rules required you to capture conductor info. If you have a system that will flag a teller when the CTR thresh hold has been reached, you have knowledge and should, from that point forward, capture all reportable transactions including conductors for the remainder of that business day. The length of the CTR is irrelevant. You must report what you know.
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Life without Jesus is like an unsharpened pencil - it has no point.

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#1669195 - 02/23/12 09:06 PM Re: Another CTR Question C.A.L.
WonderWoman Offline
Diamond Poster
WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
It looks like you need to have info on at least one of the conductors:

$10,100.00 (<-- over $10k, info required)
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#1669283 - 02/24/12 01:13 AM Re: Another CTR Question C.A.L.
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
In e-filing, the multiple persons flag does not mean that there were not multiple person involved, it only means that you have the information to complete multiple Sections A or B.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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