Is a CTR required if a customer comes in the bank and receives cash advances from credit cards >$10,000 but then immediately deposits the money into his wife's account? The customer does not come in the bank with the money and did not leave the bank with the money.

I flinch every time I read one of the little helpful hints that people use here about entering or leaving the bank with more than 10K. The reporting requirement is triggered by deposits, withdrawals, exchanges, or other payments or transfers, not by stepping over the threshold.

Your example requires a CTR.

The question is, if this was the original intent of the customer, why was cash involved in the transaction at all. This may be a processing issue on your front line.

Agreed. Unless the customer parsed out his instructions and the teller was not aware of the entire plan, there was no need to take the cash out of the drawer.

If this is a scenario where suspense is masquerading as cash, but no currency was actually exchanged, then there is no currency transaction to report.

However, if currency was actually handed to the customer- even if it was handed back right away- then it is a currency transaction, and it is reportable.

Like Ken and Randy said- review your processing steps. There should be a way to process multi-step non-cash transactions without recording them as cash.

I tell my front line staff that their window is the toll booth. It's money crossing in the same direction over the line.

As someone who used to discuss questions like this in terms of what the customer entered and left with, I confess to being a complete convert to the idea that it's control of the funds (in other words, the handing over of cash at the teller window) that is the trigger. If the funds didn't cross the teller window line to or from the customer, there's no cash transaction. But if they do cross, the transaction happens.

I have spoken to the teller, and no cash was taken out of the drawer for this transaction. Therefore, we will not file a CTR. However, cash-in and cash-out tickets were printed for the transaction so it gives the appearance of a cash transaction. We will work with our front line on the processing issues with our tickets. Thanks for everyone's help!

Some transactions may generate a "false positive" in the software; they excite examiners and auditors too. No currency, no Currency Transaction Report.

Document. Document. Document.