Thread Options
#1979877 - 12/01/14 03:31 PM CTR - one cash out ticket = one transaction?
Madawaska Offline
100 Club
Joined: Sep 2008
Posts: 105
VA
Sorry to beat a dead horse --

A non-customer cashes two on-us checks (each under $10,000, but together aggregate over $10,000)at the same time in the branch; one cash out ticket is produced.

Does the multiple transactions box need to be checked?

Is is 'multiple' because of two items, or since one cash out ticket is produced, it is one transaction.

I'm probably over-thinking this, but want to make sure.

Return to Top
BSA/AML/CIP/OFAC Forum
#1979881 - 12/01/14 03:42 PM Re: CTR - one cash out ticket = one transaction? Madawaska
CULady Offline
Gold Star
Joined: Sep 2007
Posts: 493
WA
I always thought of multiple transactions to be transactions done at different times. Or did one cash withdrawal on account A and then did a cash withdrawal on account B.
If I were filing I would NOT mark multiple transactions.
And yes you are overthinking especially for pre-coffee Monday morning! :P

Return to Top
#1979914 - 12/01/14 05:00 PM Re: CTR - one cash out ticket = one transaction? Madawaska
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Think of the CTR as a "tracer" document. Someone hands it to you 5 years later and says "I want to see the supporting documentation." Are you looking for one cash transaction in the amount of cash shown on the CTR or are you looking for multiple cash transactions that add up to the amount of cash shown on the CTR?"

For example, if there's only one cash out ticket that offsets two checks, it's not a "multiple" transaction. (The amount on the single ticket would be the same as the cash amount of the CTR.) If we processed three night deposits and each had it's own cash in ticket then I would check "multiple." So, when I start my research months or years later I will know before I begin that there is no single cash transaction in the amount of the CTR.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1981201 - 12/05/14 01:51 PM Re: CTR - one cash out ticket = one transaction? Madawaska
CFR31 Ch x Offline
Junior Member
Joined: Dec 2014
Posts: 31
Be consistent and update your policies and procedures on how you're going to handle these situations.

Return to Top
#2235460 - 04/22/20 06:58 PM Re: CTR - one cash out ticket = one transaction? Madawaska
LA Guns Offline
New Poster
Joined: Dec 2015
Posts: 24
What if a husband comes in and deposits into the checking account in the morning and the wife comes in that afternoon and deposits into the same checking account and they both add up to $11,000. If you do mark "multiple" transactions, who would it be on? Neither the husband or the wife conducted "multiple" transactions; however, there were 2 deposits into the account.

Return to Top
#2235463 - 04/22/20 07:09 PM Re: CTR - one cash out ticket = one transaction? Madawaska
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,310
Galveston, TX
Multiple transactions (indicator). This element declares that multiple cash in or cash out transactions of any amount were conducted in a single business day by or for party. “Multiple transactions” is not the same as “Aggregated transactions,” which only involves multiple transactions all of which are below the reporting requirements.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2235480 - 04/22/20 09:01 PM Re: CTR - one cash out ticket = one transaction? Madawaska
LA Guns Offline
New Poster
Joined: Dec 2015
Posts: 24
I'm sorry rlcarey, but I am not following what you are trying to say. I am aware of the requirements of "aggregated" transactions. Are you stating that "aggregated" transactions should be marked because both transactions were under the threshold? They did identify the individuals (both). Does that matter?

I was with the understanding that if there were more than one transaction to an account than "multiple" transactions should be marked; however, neither party did multiple transactions.

I apologize that I am not explaining myself very well!

Return to Top
#2235481 - 04/22/20 09:05 PM Re: CTR - one cash out ticket = one transaction? Madawaska
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,310
Galveston, TX
Those are not my words, those are the instructions. You had one transaction in the morning and you had one transaction in the afternoon. Since they were deposits, they benefitted whoever the owner's might be of this checking account. Therefor you have "multiple cash in transactions of any amount conducted in a single business day for party".
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z