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#1857495 - 10/01/13 10:02 PM Foreign Currency Out - CTR Question
bankerdiva2 Offline
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Conductor makes deposit of cash for 11,000 to account A on behalf of business and transaction is reported on item 21 for business and coonductor. Conductor also received 100,00 pesos on behalf of business same day(the Bank debited account B for the pesos which were ordered from our correspondent). Will I only complete line 28 Foreign Cash Out? It seems strange to me that the conductor is not being reported for receiving the pesos and no account number is being reported for the foreign cash out.
Last edited by bankerdiva2; 10/01/13 10:06 PM.
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#1857530 - 10/02/13 12:41 PM Re: Foreign Currency Out - CTR Question bankerdiva2
Erl of Baltimore Offline
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I have a question for this scenario and maybe someone here can help me. By purchasing the 100,000 pesos with US dollars and the current exchange rate I have seen is roughly $.08 of a dollar, that makes the puchase only worth $7,800 in US dollars. Would the peso purchase even be reflected on the CTR?

Any help would be appreciated.
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#1857532 - 10/02/13 12:52 PM Re: Foreign Currency Out - CTR Question bankerdiva2
Erl of Baltimore Offline
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I think I found the answer on the FINCEN website. Here is what I found:
It looks to me the 100,000 peso purchase would not be entered onto the CTR because using the current day's exchange rate i saw of $.076 would only amount to $7,600 and thus be under the $10,000 reporting threshold.

1. What should be entered in items 26 and 27?

If cash received totals over $10,000, enter the total amount of cash received in item 26 (“Total cash in”). If cash disbursed totals over $10,000, enter the total amount of cash disbursed in item 27 (“Total cash out”). Always enter the total dollar amount in items 26 and 27 using the U.S. dollar equivalent. If foreign currency is involved as part of the transaction, use the current business day’s exchange rate to determine the total amount in U.S. currency to enter.

“Cash-in” and “Cash-out” transactions should be considered separately, and not aggregated. However, they may be reported on a single CTR by using both items 26 and 27. (See example three and four in the CTR Instructions, or on the FinCEN web site at http://www.fincen.gov/fin104_ctr.pdf). If there is a currency exchange, it should be aggregated separately with each of the cash in and cash out totals. Since the currency exchange was one of the transactions that caused the CTR to be created, the bank must mark the “Currency Exchange(s)” box in item 33. In addition, with respect to the currency deposit or withdrawal the bank must mark the box for “Deposit(s)/Withdrawal(s)” in item 34, and the box for “Account Number(s) Affected (if any)” in item 35. Finally, the bank must disclose in item 35 the number of the savings or deposit account affected by the withdrawal or deposit.
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#1857533 - 10/02/13 12:54 PM Re: Foreign Currency Out - CTR Question bankerdiva2
edAudit Offline
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I am not sure of the question if peso are greater than $10,000 US a CTR is needed if the amount of Pesos are less no CTR.

If it is a mix and over $10,000 us see below (this is from 2005 so it may not line up with the online form).

If foreign currency is involved as part of the transaction, use the current business day’s exchange rate to determine the total amount in U.S. currency to enter.

http://www.fincen.gov/statutes_regs/guidance/pdf/faq08122005.pdf
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#1857773 - 10/02/13 06:24 PM Re: Foreign Currency Out - CTR Question bankerdiva2
bankerdiva2 Offline
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But my cutomer did not "exchange" currency. The account was debited by the bank, no cash was given by the customer for the peso purchase.

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#1857784 - 10/02/13 06:42 PM Re: Foreign Currency Out - CTR Question bankerdiva2
RockChucker, CAMS Offline
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The Country
Did you just "give" the customer the pesos or did you "exchange" the pesos for money from an account?
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#1857819 - 10/02/13 07:27 PM Re: Foreign Currency Out - CTR Question bankerdiva2
bankerdiva2 Offline
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We debited the customer's account just as if he had written a check.

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#1857874 - 10/02/13 08:55 PM Re: Foreign Currency Out - CTR Question bankerdiva2
John Burnett Offline
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Count the USD equivalent of the pesos to determine whether you have to file a cash-out CTR. In the original post this is the only cash-out transaction conducted by the individual or on behalf of the company that day. So the customer's receipt of the pesos is not reported at all on a CTR because the USD amount is less than $10K. Stick to reporting the deposit.
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#1857895 - 10/02/13 09:39 PM Re: Foreign Currency Out - CTR Question bankerdiva2
bankerdiva2 Offline
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John, the USD equivilent was $11,314.39 (I was just rounding in my original question). I have tried to call the Regulatory Hotline to get help with this question, however they are closed due to the Government shutdown. Thankfully this is an amendment, so I'm not under pressure for the 15 day reporting requirement, but I would like to resolve ASAP as I have auditors due in shortly.
What a mess the shutdown is, what if I did have a reporting deadline???!!!

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#1858043 - 10/03/13 03:11 PM Re: Foreign Currency Out - CTR Question bankerdiva2
John Burnett Offline
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OK. I didn't see your post at the start of this thread. What the original CTR should have looked like:

Part I for business with boxes 2c and 3 checked. Item 21 $11,000, with account number for Account A. Item 22 $11,315, with account number for Account B.

Part I for the individual with boxes 2b and 3 checked. Items 21 and 22 same as for the business.

Part II with $11,000 in item 25a and $11,315 in item 27a (this isn't a currency exchange, it's a withdrawal). Put 100,000 in item 28 and select Mexico as the foreign country.

If instead of debiting account B you had the customer produce a check for the correct USD amount, the entry in 27a would go in 27d, instead.
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#1859478 - 10/08/13 04:24 PM Re: Foreign Currency Out - CTR Question bankerdiva2
bankerdiva2 Offline
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John,
Thank you so much for clarifying this for me. My apologizies for not getting back to you sooner. You are the BEST!!!!
Last edited by bankerdiva2; 10/08/13 04:25 PM.
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