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#1737129 - 08/31/12 02:21 PM CTR FinCEN -Multiple vs Agrgregated
Sunshine Banker Offline
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FinCenCTR-Completion #3 or #24 Nigh Deposit, Aggregated-both #3 and #24 Our business client deposited several envelopes in the night depository for processing. Individually the cash in each envelope did not total more than $10,000,but when added together did trigger the CTR reporting requirements. Refresh my memory please.

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#1737146 - 08/31/12 02:35 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
John Burnett Offline
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Check box 3 in Part I to indicate you're reporting on multiple transactions. Check "night deposit" and "aggregated transactions" in item 24 to indicate that one or more of the transactions was in the night drop and that you don't have conductor information because none of the transactions would have triggered a CTR by itself.
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#1780750 - 01/29/13 05:18 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
morirse de risa Offline
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What if you have a night deposit transaction and an in-person transaction which individually do not exceed $10,000, but together do? I can identify the conductor of the in-person transaction and plan on completing a Part I 2b for that person. Should I still check the "aggregated transactions" box?

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#1780768 - 01/29/13 05:27 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
John Burnett Offline
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IMO, yes. You don't know who made the night deposit. Now if you DO know who made the deposit, and have the info on him/her, you complete a "conductor" entry on him/her. If he/she happens to be the same individual who made the in-person deposit, include the night deposit in the amount you report on that individual's "conductor" page.
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#1780790 - 01/29/13 05:50 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
morirse de risa Offline
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OK - thanks for your help!

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#1780829 - 01/29/13 06:38 PM Re: CTR FinCEN -Multiple vs Agrgregated morirse de risa
Elwood P. Dowd Offline
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The instructions for the CTR have been revised twice since its publication. The current version for 24(e) says in part:

Check box 24e “Aggregated transactions” if the financial institution did not identify any of the transactor(s) because the FinCEN CTR reports aggregated transactions, all of which was (sic) below the reporting requirement, and at least one of the aggregated transactions was a teller transaction.

The instructions do not contemplate that all of the transactions would be below $10K, but you would still have identified a person conducting the transaction. (Many banks do identify any person conducting the transaction for amounts well below 10K.) Regardless, my assumption is that, since one "transactor" will be identified on the form, the box should not be checked.

You can flip a coin between my response and John's and I would not be offended, but if I wanted to withstand criticism for accepting either opinion I would call the Helpline.
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#1781137 - 01/30/13 03:44 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
morirse de risa Offline
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I called the Helpline this morning to see what they would say. She told me that I would check the aggregated transactions box since I did not know who completed the night deposit transaction.

Thanks again for both of your help - I appreciate it!

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#1782114 - 02/01/13 04:49 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
DoorKey Offline
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A comment was made: The instructions for the CTR have been revised twice since its publication.

How are we to know when instructions have been changed? I do not recall any email alerts from FinCEN. Within BSA e-File the version number of the CTR form remains the same, yet the instructions for 24(e) have changed. Frustrating...

If you can point me to places where changes are posted I would appreciate it. Thanks.
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#1782169 - 02/01/13 06:04 PM Re: CTR FinCEN -Multiple vs Agrgregated DoorKey
Elwood P. Dowd Offline
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The current instructions for each of the 3 new reports are linked in the lower right hand corner of the User Test System homepage. At the beginning of each is a "revision history" that recaps the changes made since the previous set of instructions. (They are undoubtedly updating the instructions in response to the questions they have fielded to date.)

If you saved and marked up the first set as I did, the revision histories will bring you up to speed. 24e is only an example, several instructions have been changed. The only thing better would be if they did not change them at all...
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#1782301 - 02/01/13 08:39 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
PeeWee Offline
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In our shop, we've felt alot of confusion over the aggregate transaction box as well. Unless I missed something, it appears that a Q&A slide from FinCEN's webinar presentation (page 87) represents Good2bank's question.

FinCEN webinar

Q: In the FinCEN CTR, when would I use the “Multiple Transactions” box and the “Aggregated Transactions” box?

Scenario II:
A bank receives two night deposits (each transaction below the reporting threshold) that totaled over $10,000 that are to be deposited into one business account.

The financial institution would file a CTR by completing a Part I on the entity to which the account, where the funds being deposited, belongs by selecting Item 2c (Person on whose behalf transaction was conducted) and Item 3 (Multiple Transactions). Additionally, the financial institution would select “Night Deposit” in Item 24 as no identifying information on the transactor was collected; “Aggregated Transactions” would not be selected in this scenario as none of the deposits was a teller transaction.


Because of the confusion on the aggregate box, I called FinCEN some time ago with a question similar to morirse de risa. The scenario I gave involved an in person deposit, where we had identified the person, and an ATM deposit. Each transaction was below the CTR limit but reportable when aggregated. The answer was yes, the aggregate box would be checked. This ties back to the MAJORITY of the CTR instructions on aggregate (each transaction was below the amount and one was a teller transaction). What it doesn’t tie back to is “the FI did not identify any of the transactors”. But the FinCEN rep said if you have their information put it on the form.

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#1792842 - 03/08/13 05:10 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
Getting_Grayer Offline
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Ken,

Can you provide where I may obtain the latest copy of the FinCEN Currency Transaction Report Electronic Filing Requirements. The copy I have is as of March 2012. I follow the link you provided above, but I do not see the document there. I have also searched FinCEN's site to no avail.

Thank you for the assistance.

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#1792850 - 03/08/13 05:16 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
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#1792925 - 03/08/13 06:06 PM Re: CTR FinCEN -Multiple vs Agrgregated Getting_Grayer
Elwood P. Dowd Offline
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The links to all of the forms are in the column at the far right at the top. The links to all of the instructions are in the far right column at the bottom.
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#1792926 - 03/08/13 06:07 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
Getting_Grayer Offline
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Thank you!

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#1792930 - 03/08/13 06:09 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
Getting_Grayer Offline
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Ken,

I highlighted the area and found that it is a scrollable box, which for some reason does not show on my browser. Thank you for the assistance. Randy, thank you for the link.

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#1793045 - 03/08/13 09:00 PM Re: CTR FinCEN -Multiple vs Agrgregated Elwood P. Dowd
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The current version does state,"and....was a teller transaction." However, when you are completing the form and hold over the instructions on the screen for #24, the words, "and...was a teller transaction" are not on the screen instructions. Does this make a difference? And why aren't the instructions the same? Thanks for all your help.

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#1793127 - 03/09/13 01:43 PM Re: CTR FinCEN -Multiple vs Agrgregated 2old2new
Elwood P. Dowd Offline
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No, it does not make a difference; you would check the box under the same circumstances.
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#1801550 - 04/04/13 05:56 PM Re: CTR FinCEN -Multiple vs Agrgregated Elwood P. Dowd
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What about this Scenario:
One identifed individual conducts two transactions: (1) $10,000 cash back on a deposit, and (2) $100 cashed check.

Would this be correct:
a) Person conducting transaction on own behalf and Multiple transaction boxes are checked.
b) Cash Out amounts of the Withdrawal ($10000) and Negotiable instrument cashed ($100) are totaled but Aggregated transactions box is NOT checked because the one transactor was identifed.

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#1801621 - 04/04/13 07:47 PM Re: CTR FinCEN -Multiple vs Agrgregated BjK
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it would be Aggregated because neither transaciton is reportable on its own. It would have to be $10,000.01 to be reportable.

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#1801624 - 04/04/13 07:49 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
MrsSmithCRCM Offline
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I disagree. There would be multiple transactions, but aggregated is used when you did not collect the transactor information because it was under the threshold. In this case- you have the info, you don't check aggregated.

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#1801627 - 04/04/13 07:53 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
MrsSmithCRCM Offline
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Further, if you hover above the aggregated box- it says to check aggregated when transactor info was not collected because of the reporting amount being under the threshold. It goes on to say that it is not the same as multiple, which CAN be used for amounts over the threshold, (emphasis added that it CAN be used, not that it HAS to be used that way).

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#1948483 - 08/01/14 09:55 PM Re: CTR FinCEN -Multiple vs Agrgregated PeeWee
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The final sentence of PeeWee's post: FinCEN stated to put in transactor information, even though the aggregate box is checked (due to separate transactions throughout the day not exceeding the threshold) --- are banks currently doing this?

Example: If ABC Company has a $5,000 deposit in the AM from transactor A, and a $7,000 deposit in the PM from transactor B, FinCEN is requiring we identify transactor B? I want to confirm that I am understanding these posts correctly.

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#1948493 - 08/01/14 10:22 PM Re: CTR FinCEN -Multiple vs Agrgregated Sunshine Banker
BrianC Offline
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If you have aggregation software or a process in place that is capable of identifying when the $10,000 threshold is exceeded, then you should identify the second person making the deposit. However, if your current system does not support aggregation, then you would not have identified any of the individuals making the deposits and would check "Aggregated transactions" as your reason for not identifying any of the conductors in Part I.
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