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#1788489 - 02/22/13 05:48 PM New CTR Aggregation Question
CantBeShocked Offline
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This strictly may be a software vendor issue but we can't find anything in the FinCEN instructions to verify that the change is correct.

Scenario - you have a customer who makes a deposit into his checking account for $12,000.52 and a loan payment on his personal loan for $10,000.09. In the past, you previously totalled the two transactions together ($22,000.61) and then rounded up to $22,001 for the CTR.

HOWEVER - our CTR software rounds the deposit to $12,001 and the loan payment to $10,001, places each amount on the correct line in on teh CTR and then totals them to $22,002.

We cannot find anything in the FinCEN tech specs for the new form or any instructions that state that individual transaction type rounding is appropriate.

Hoping somone here has some input. We are also calling our vendor to ask why they are doing it this way.

Thansk.
Last edited by The Real Mobo; 02/22/13 05:50 PM.
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#1788500 - 02/22/13 05:59 PM Re: New CTR Aggregation Question CantBeShocked
rlcarey Online
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13. Monetary amounts: Record all U.S. Dollar amounts rounded up to the next whole dollar. The amount $15,265.25 would be recorded as $15,266. A foreign currency amount can only be recorded in Item 26 “Foreign cash in” or Item 28 “Foreign cash out,” again rounded up to the next whole amount. When converting a foreign currency to dollars use an exchange rate for the date of the transaction.
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#1788507 - 02/22/13 06:05 PM Re: New CTR Aggregation Question CantBeShocked
CantBeShocked Offline
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You aren't answering the question I asked - please read the scenario again and what is happening.

It is a CTR aggregate with two different transaction types.
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#1788510 - 02/22/13 06:13 PM Re: New CTR Aggregation Question CantBeShocked
Elwood P. Dowd Offline
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You aren't reading the answer he gave you. It's an excerpt from the instructions. Your software is operating per the instructions.
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#1788513 - 02/22/13 06:18 PM Re: New CTR Aggregation Question CantBeShocked
John Burnett Offline
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The instruction that Randy supplied is the instruction for entering dollar amounts for e-filing. Each transaction is rounded up. The old form only asked for one cash-in or cash-out amount; the new one asks for the breakdowns. Round all fractional amount inputs up to the next whole dollar.
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#1788527 - 02/22/13 06:39 PM Re: New CTR Aggregation Question CantBeShocked
CantBeShocked Offline
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But it doesn't say Transaction - it says Dollar amounts which could mean the total.
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#1788531 - 02/22/13 06:46 PM Re: New CTR Aggregation Question CantBeShocked
John Burnett Offline
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The dollar total for item 25 accumulates automatically.

Wherever you input a dollar amount that is not in whole dollars, round up to the next whole dollar.
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#1788532 - 02/22/13 06:48 PM Re: New CTR Aggregation Question CantBeShocked
Elwood P. Dowd Offline
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#1788536 - 02/22/13 06:59 PM Re: New CTR Aggregation Question CantBeShocked
CantBeShocked Offline
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I went into FinCEN's site and pretended to load an individual CTR and I finally got it - thanks for your patience!!!

Part of our misunderstanding is that our software vendor didn't really change the screens to match the new CTR format - even though they changed the "Preview CTR" screens to do so. It makes it very confusing.

Wanda
Last edited by The Real Mobo; 02/22/13 07:11 PM.
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