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#1771339 - 12/31/12 05:40 PM CTR Help
BSAAnonymous Offline
100 Club
Joined: Feb 2012
Posts: 165
We have a customer who is Phase 1 - exempt. A non-customer makes a cash deposit of $11,000 into the Phase 1 customer's account. A CTR would be generated on the individual making the cash deposit. However, the benefitor would be the Phase 1 exempt customer eventhough they are exempt? Thanks........

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#1771341 - 12/31/12 05:43 PM Re: CTR Help BSAAnonymous
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
A CTR would not be required in this situation.
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Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1771344 - 12/31/12 05:52 PM Re: CTR Help BSAAnonymous
BSAAnonymous Offline
100 Club
Joined: Feb 2012
Posts: 165
Thanks, Kelsey. Can I ask why not?

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#1771346 - 12/31/12 05:57 PM Re: CTR Help BSAAnonymous
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
Transactions done on behalf of an exempt customer are exempted from CTR reporting regardless of who conducted the transaction.
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1771347 - 12/31/12 05:59 PM Re: CTR Help BSAAnonymous
BSAAnonymous Offline
100 Club
Joined: Feb 2012
Posts: 165
Thank you, Kelsey.

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#1771371 - 12/31/12 07:15 PM Re: CTR Help BSAAnonymous
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,651
Galveston, TX
"A non-customer makes a cash deposit of $11,000 into the Phase 1 customer's account."

What exactly does this mean?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1771378 - 12/31/12 07:48 PM Re: CTR Help BSAAnonymous
BSAAnonymous Offline
100 Club
Joined: Feb 2012
Posts: 165
Our customer is the receiver of taxes who is exempt. An individual deposited $11,000 into our customer's account to pay their taxes.

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#1771411 - 01/01/13 01:38 PM Re: CTR Help BSAAnonymous
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,651
Galveston, TX
A governmental taxing authority authorizes the bank to receive direct payments from customers for deposit into their account? That is a little unusual.

However, the deposit would be exempt.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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