Thread Options
#2005225 - 03/31/15 03:23 PM CTR Aggregation involving a Trust
BSAsport Offline
New Poster
Joined: Jul 2013
Posts: 19
Jan Brady, co-trustee withdraws $22,000 in cash from a grantor trust account (Mike and Carol Brady Declaration of Trust) established with Mike Brady's SSN. On the same day, Mike Brady performed a $200 ATM withdrawal from his sole owner account. On the next business day, a CTR was system-generated based on primary TIN aggregating both cash-out transactions totaling $22,200.

Should the $200 ATM withdrawal be incldued as part of this reportable transaction?

Return to Top
BSA/AML/CIP/OFAC Forum
#2005526 - 04/01/15 02:36 PM Re: CTR Aggregation involving a Trust BSAsport
BSAsport Offline
New Poster
Joined: Jul 2013
Posts: 19
Can anyone opine?

Return to Top
#2005535 - 04/01/15 02:47 PM Re: CTR Aggregation involving a Trust BSAsport
kw004h Offline
100 Club
Joined: Nov 2009
Posts: 219
Chicagoland, IL
I'm going to make some assumptions (and we all know what happens when one assumes...etc....)

In withdrawing $22,000 from her parents' trust while acting as trustee, I will assume that Jan was acting on behalf of one or both of her parents, and not on her own behalf. (your teller may even have asked that question while processing the withdrawal, since you would need that information in order to properly complete the CTR that was prompted by that transaction.)

I will assume Jan indicated she was conducting the transaction on Mike's behalf, in which case, you do add the $200 ATM withdrawal as part of the reportable transaction.

Return to Top
#2005564 - 04/01/15 03:46 PM Re: CTR Aggregation involving a Trust BSAsport
PrimeTime Offline
100 Club
PrimeTime
Joined: Nov 2014
Posts: 173
Without all the details of the transaction, as kw004h pointed out (because there may have been a conversation with the teller), I would say that the $200 ATM withdrawal would not be aggregated.

My system does something similar with the aggregation based on the primary TIN, however from the sounds of this transaction, that truly isn't the case.

The withdrawal from $22,000 was conducted by Jan Brady, and as far as we know from the details given, benefitted by Jan Brady, because she was the individual that walked out of the Bank with the cash. What she did with it after she left (unless she stated a purpose to the teller) is out of the Bank's hands, and should not be assumed (we all know what happens when you do that!)

The ATM withdrawal was conducted and benefitted by Mike Brady, so unless it was explicitly stated by Jan that the $22,000 withdrawal was going to benefit Mike, then it would be considered separate.

Pending additional details, I would file for just the $22,000.
_________________________
Life is like a bicycle. To keep your balance, you must keep moving.
-Albert Einstein

CAMS

Return to Top

Moderator:  Andy_Z