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#1693230 - 04/27/12 12:44 PM CTR exemption status
RBanker Offline
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RBanker
Joined: Jul 2003
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Austin Texas
Let's say you have a Phase 2 Exemption for a customer - and it's been in place for 2+ years.
If an officer of your bank brings in a deposit for the customer (don't even go there, I've got that covered - - eek) - is that exemption affected? Would you need to file a CTR because the deposit was transacted by a bank employee, outside of the expected norm of the transaction relationship....

Last edited by R Banker; 04/27/12 12:46 PM.
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#1693235 - 04/27/12 12:48 PM Re: CTR exemption status RBanker
rlcarey Offline
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Galveston, TX
Not as long it involved a deposit to their account, it doesn't matter who the conductor might have been.
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#1693239 - 04/27/12 12:53 PM Re: CTR exemption status RBanker
RBanker Offline
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Austin Texas
That's what I'm thinking - that the exemption covers all transaction, regardless of transactor - just wanted to make sure that there wasn't some kind of an arcane, little-used rule about bank employees involvement. Thanks
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#1693260 - 04/27/12 01:26 PM Re: CTR exemption status RBanker
rlcarey Offline
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Galveston, TX
Well, technically, the employee did not make the deposit. The person that made the deposit is the customer's employee that handed the cash to the employee. If this was not an exempt customer, the employee would have had to obtain that information at that time for the CTR.
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