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#1852878 - 09/17/13 03:55 PM Include the children? CTR
Bec Offline
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Bec
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Posts: 1,115
The Great White North
Hello all,
A mother has two minor children. She has 1 check per child from social security for $13,000. She opens a savings account jointly owned with each child for $1000 and then cashes out a total of $24,000. The checks were written payable to: Mother FOR minor child. For the CTR should I put the mother and the two minor children as "person on whose behlaf transaction is conducted" and then the mother as the "transactor" Or do I just report the mother?
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#1852944 - 09/17/13 05:17 PM Re: Include the children? CTR Bec
athomas@bankcsb.com Offline
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athomas@bankcsb.com
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Midwest
I would include the children on the CTR and file a SAR on the mother. Were these set up as UTMAs, custodial or just joint accounts?

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#1852972 - 09/17/13 06:01 PM Re: Include the children? CTR Bec
devsfan Offline
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I would also wonder why the chldren needed $24,000 in cash.

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#1852988 - 09/17/13 06:21 PM Re: Include the children? CTR devsfan
athomas@bankcsb.com Offline
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athomas@bankcsb.com
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Unfortunately we too often see parents come in with checks FBO their children and when they deposit them into the childrens account they just turn around and transfer it into their own for their own personal use.

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#1853008 - 09/17/13 06:56 PM Re: Include the children? CTR Bec
JacF Offline

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While I agree that this is unusual, I wouldn't pull the SAR trigger without first completing an investigation.

Where does the mother bank? What are the circumstances surrounding the lump-sum payout? What expenses had already been paid by the mother in anticipation of this payout? Why take so much in cash? These are all questions that are worth asking before going to a SAR.

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#1853010 - 09/17/13 07:00 PM Re: Include the children? CTR Bec
Bec Offline
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Bec
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So I agree that we should probably put the children on here since the checks were FOR them. HOwever would I put the mom as the beneficial owner as well as the transactor? I thought I remember that you don't want to have a transactor the same as a person for whom the transaction is for. Anyone recall?
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#1853017 - 09/17/13 07:06 PM Re: Include the children? CTR Bec
JacF Offline

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Originally Posted By: Bec
I thought I remember that you don't want to have a transactor the same as a person for whom the transaction is for. Anyone recall?


There is no prohibition against this. In fact, the CTR specifically allows for it by including Box 2a: Person conducting transaction on own behalf.

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#1853360 - 09/18/13 04:16 PM Re: Include the children? CTR Bec
Bec Offline
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Bec
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So just to clarify, I can put the mom as a person on whose behalf transaction is conducted and then also put her as the transactor?
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#1853368 - 09/18/13 04:26 PM Re: Include the children? CTR Bec
devsfan Offline
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On the new CTR format she will be shown as Box 2a as JacFSB indicated.

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#1853371 - 09/18/13 04:34 PM Re: Include the children? CTR Bec
Bec Offline
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Bec
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Perfect. Thank you all for your help!
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