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#1739783 - 09/11/12 03:38 PM Using ATM transactions for CTR
namwalhsif Offline
Junior Member
Joined: Feb 2012
Posts: 34
Texas
When aggregating ATM transactions for CTR's, how are others handling joint accounts where it could be the other party on the account withdrawing funds from the account or somone who was given permission to withdraw funds from the ATM?

Thanks in advance for information.
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#1739794 - 09/11/12 04:03 PM Re: Using ATM transactions for CTR namwalhsif
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
Since we always show all parties on the account in CTRs for both deposits and withdrawals this is not an issue. Insofar as a 3rd party using the ATM card I would think it is very rare and I would prepare the CTR in the usual manner.

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#1739832 - 09/11/12 05:02 PM Re: Using ATM transactions for CTR namwalhsif
CompliKat Offline
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CompliKat
Joined: Dec 2009
Posts: 96
Devsfan, Am I understanding that you include all owners of an account on the CTR even if only one physically withdrew the funds? We do include all owners for deposits but not cash-out scenarios. Also do you include all parties on the account,to include authorized signers? Just curious, I have not ever considered this an option. And do your examiners support this method? Hmmmm... thinking on this.

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#1739898 - 09/11/12 06:13 PM Re: Using ATM transactions for CTR namwalhsif
namwalhsif Offline
Junior Member
Joined: Feb 2012
Posts: 34
Texas
Here is a description of the transaction we are questioning. Husband comes to bank and withdraws $5K. Wife goes to another branch and withdraws $5K. Later that day child goes to ATM and uses mom and dad's debit card and withdraws $40.00. Next day we are looking to do a CTR but do not know who to list as what. To complicate the issue a little more Child used Mom's debit card (with permission) and is not on accout with parents (16 y/o) but has account with bank...
Last edited by namwalhsif; 09/11/12 06:14 PM.
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#1739909 - 09/11/12 06:36 PM Re: Using ATM transactions for CTR namwalhsif
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
I hate to question the obvious here, but just how did you know that the $40 ATM transaction was completed by Junior and not by his Mom? If I knew that the kid made that $40 withdrawal, I would not consider the withdrawal as being on behalf of Mom. I'd say it was on Junior's own behalf. And that would take the CTR off the table.

But I'd think about whether the parents' withdrawal pattern might be consistent with structuring.
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#1739922 - 09/11/12 07:15 PM Re: Using ATM transactions for CTR namwalhsif
namwalhsif Offline
Junior Member
Joined: Feb 2012
Posts: 34
Texas
Sorry, mom came in next day and deposited $5K as they both were withdrawing funds to pay for a large purchase did not know the other one had already done so until they got home. We know the kid has his moms card and withdraws $40 each week for lunch money as that is what they told us. That is the issue we dont know for sure who took the $40.00 and our reports show we have a withdraw from the single account in the amount of $10,040 with mom taking 5K and dad taking another 5K and then ATM $40... How should we file the CTR?
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#1739933 - 09/11/12 07:43 PM Re: Using ATM transactions for CTR namwalhsif
CompliKat Offline
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Joined: Dec 2009
Posts: 96
Ok first, what kind of amazing reports do you get that give you that much info, and can I have it too!!!! Mine don't aggregate ATM transactions at all.

I'm thinking that the son's transaction is not part of anything reportable, almost like Mom wrote him a check and he happened to cash it on the same day they wanted to make a large purchase, and thus no reportable threshold crossed. I am glad to see you have an explanation for the withdrawals that could appear structured.

Still curious about reporting all parties on an account for withdrawals... does anyone else do this?

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#1739951 - 09/11/12 08:43 PM Re: Using ATM transactions for CTR namwalhsif
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
CompliKat, there have been alot of threads about withdrawal CTRs and the general consensus is that it is better to show all account owners on CTRs for deposits and withdrawals. Until recently we held out and only did it for deposits but decided to go with the flow.

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#1740162 - 09/12/12 04:29 PM Re: Using ATM transactions for CTR namwalhsif
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
I think you have enough background on the track record of the account to believe that the $40 ATM withdrawal was done by the kid, and it's clearly on his own behalf, not on behalf of Dad or Mom. That makes the rest of the scenario moot, since the CTR trigger wasn't pulled even if you do attribute withdrawals to both joint owners.
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