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#1744708 - 09/27/12 02:28 PM CTR for ATM withdrawal
KRT Offline
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Joined: Nov 2006
Posts: 59
Southeast US
Our report shows that a customer cashed a check for $10,000, and had a $100 ATM withdrawal from his account. At this point, do you proceed with filing a CTR, or do you call the customer to find out who actually did the ATM transaction (could be a different joint owner)?

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#1744828 - 09/27/12 04:58 PM Re: CTR for ATM withdrawal KRT
devsfan Offline
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NYC
Since the common practice is to include all account-holders on a CTR for both deposits and withdrawals you should certainly aggregate these transactions and file a CTR.

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#1744844 - 09/27/12 05:18 PM Re: CTR for ATM withdrawal KRT
Cape Codder Offline
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ALthough your account may be joint, aren't your ATM cards issued to specific individuals? You should be able to determine who conducted the withdrawal based on the card number. Sorry - have never been a proponent of listing all joint account owners on a CTR simply because one owner conducted the withdrawal - unless, of course, the Bank has knowledge that the funds benefited more than just the conductor.
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#1744887 - 09/27/12 06:01 PM Re: CTR for ATM withdrawal Cape Codder
Dani York, CRCM Offline
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TN
Originally Posted By: Cape Codder
ALthough your account may be joint, aren't your ATM cards issued to specific individuals? You should be able to determine who conducted the withdrawal based on the card number. Sorry - have never been a proponent of listing all joint account owners on a CTR simply because one owner conducted the withdrawal - unless, of course, the Bank has knowledge that the funds benefited more than just the conductor.


Ditto
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#1745584 - 10/01/12 06:48 PM Re: CTR for ATM withdrawal KRT
CompliKat Offline
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We do not ever include all joint account owners for withdrawals unless we have knowledge they were to benefit from the withdrawal. We have not been criticized for this. I was unaware this was "Common Practice" until about a week ago. I'm not quite ready to make assumptions about whether JTO-A is sharing the withdrawn funds with JTO-B and so forth. We go with the facts we know, who was present, what they said to us, etc. And if there is something suspicious to the withdrawals then we jump off from there. Does everyone list all owners on CTRs for withdrawals, and is there some specific guidance out there that I slept through?

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#1745708 - 10/02/12 10:21 AM Re: CTR for ATM withdrawal CompliKat
Elwood P. Dowd Offline
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Here's one of several prior threads. In essence, the only available guidance says that if the party making the withdrawal makes an affirmative statement that he is withdrawing the funds on his on behalf and you believe him, it is not necessary to list the other owners. Much has changed since I was a teller, but I don't think people automatically make such statements.

As noted, "consistency" in your interpretation would actually be more important than the interpretation itself. The amount of time devoted to discussing this issue is some multiple of the time it deserves.
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#1745712 - 10/02/12 12:16 PM Re: CTR for ATM withdrawal KRT
devsfan Offline
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As Ken stated, isn't is easier to consistently list all account owners on CTRs for deposits and withdrawals?

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#1745733 - 10/02/12 01:12 PM Re: CTR for ATM withdrawal KRT
CompliKat Offline
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CompliKat
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Ummmm consistentlly sorry for wasting time?????

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#1745870 - 10/02/12 04:51 PM Re: CTR for ATM withdrawal KRT
devsfan Offline
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I apologize if you took my comment the wrong way. I believe it is easier to file a CTR in that manner since it would not be necessary to analyze who conducted this particular withdrawal, whose ATM card was used, etc and always file showing all account-holders. We made this change earlier this year based upon threads such as this. These threads are helpful and are not a waste of time.

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#1745997 - 10/02/12 08:13 PM Re: CTR for ATM withdrawal CompliKat
Elwood P. Dowd Offline
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Quote:
wasting time?????


There may be ample room for a second opinion about whether including all parties on the CTR is a waste of time.

Giving people responsible for filing out the forms clear directions saves time. Giving law enforcement the maximum amount of information possible might also save time. Any concerns over whether time spent is wasteful or productive would necessarily turn on whose time we are talking about.
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#1746440 - 10/03/12 09:11 PM Re: CTR for ATM withdrawal KRT
BrendaC Offline
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Sweet Home AL
ATM cards are issued to a specific cardholder. If the card used for the $100 WD was issued to the same person cashing (or benefitting from the cashing) of the $10k check, I would file the CTR. If not, I would note that info on my daily cash report and move on.
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#1747332 - 10/06/12 12:47 PM Re: CTR for ATM withdrawal KRT
Elwood P. Dowd Offline
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At least we are now certain on how to fill out the form if all parties are to be reported. From FinCEN's October 4, 2012 webinar on the CTR:

Q: How do I complete a FinCEN CTR when the funds are being deposited or withdrawn from a joint account?

Scenario: Person 1 deposits $15,000 in an account jointly owned by Customer A and Customer B.

The financial institution would file a CTR and complete a Part I for Person 1 (the transactor) by selecting Item 2b “Person conducting transaction for another" and a Part I for each, Customer A and Customer B, by selecting Item 2c “Person on whose behalf transaction was conducted”.


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#1748196 - 10/10/12 06:38 PM Re: CTR for ATM withdrawal KRT
amlzed Offline
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Joined: May 2012
Posts: 46
Another consideration is the timing of the events for possible susicious activity reporting. If the same customer conducted the teller withdrawal and immediately hit the ATM up minutes after outside the branch you could have a possible attempt to evade. I would check out the rest of their transacting history for other oddities. Good luck
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