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#2017277 - 06/01/15 02:45 PM Question regarding aggregating CTR
unknown Offline
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Joined: Apr 2005
Posts: 161
John deposits $15,000 cash into his business account.

Later in the day (at another branch), there was $100 cash deposited into the personal checking account which is owned by John and Jane. The bank does not know who deposited the $100 cash.

How would you fill out the CTR for this?

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#2017283 - 06/01/15 03:01 PM Re: Question regarding aggregating CTR unknown
thisisme08 Offline
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Joined: Oct 2012
Posts: 47
I'm assuming you've read FAQ #27?

http://www.fincen.gov/whatsnew/html/ctr_faqs.html

(Sorry, I don't have an answer for you outside of that link)
Last edited by thisisme08; 06/01/15 03:08 PM.
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#2017389 - 06/01/15 06:34 PM Re: Question regarding aggregating CTR unknown
unknown Offline
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Posts: 161
I don't think FAQ #27 applies to this situation

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#2017391 - 06/01/15 06:45 PM Re: Question regarding aggregating CTR unknown
BrianC Offline
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BrianC
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Posts: 6,721
Illinois
The business account...is it a DBA, corporation, LLC, partnership...?
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#2017395 - 06/01/15 06:48 PM Re: Question regarding aggregating CTR unknown
John Burnett Offline
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I think the question pivots on whether the bank should assume that John made the $100 deposit, which would require that it be aggregated due to his having completed the business deposit as well.

Has anyone tried asking the teller who took the $100 deposit?
Last edited by John Burnett; 06/01/15 06:51 PM.
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#2017406 - 06/01/15 07:01 PM Re: Question regarding aggregating CTR unknown
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,721
Illinois
I agree, but if the business is a DBA, then the $100 will have to be aggregated whether John made the deposit or not. If the business is a corporation and Jane deposited the $100, then the deposit would not have to be aggregated.
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#2017423 - 06/01/15 07:16 PM Re: Question regarding aggregating CTR unknown
unknown Offline
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Joined: Apr 2005
Posts: 161
The business is a corporation.

Teller does not remember who deposited the $100 cash.

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