We are filing a CTR for aggregated cash withdrawals for an over-the-counter withdrawal and an ATM withdrawal. The account is a single-owner account with 1 debit card so we know that the account-holder conducted each withdrawal but there is a difference of opinion on whether or not box 24b (ATM) should be checked on the CTR. I thought that the box is only checked if we do not know who conducted the ATM withdrawal. How should the CTR be completed? Thank you.

So I hovered the cursor over the "ATM" box on the CTR and the instructions there indicate that you would check the box if a reported transaction occurred at an ATM.

So, I think regardless of whether the conductor was identified, the ATM was involved, so the box would be checked.

I agree with "It's OK", that you should check 24b.

However, from your question I'm not sure if you are also checking the 'aggregated' box or not. If I read that same section correctly, this would not be an aggregated transaction, but multiple transactions, no?

Upon further review it is clear that 24b should be checked. We will not check Aggregated but will check Multiple on Part 1. Thanks for the responses.

We have unique RSSD numbers for each branch location which are reflected in "Line Item 39" (Financial institution ID number). Should a unique RSSD number be reflected for activity conducted at an ATM?

^Bump...can anyone opine? Thank you!

No, it's the branch, not the ATM, that has an RSSD. Not all ATMs are at branches and you would be setting a precedent you could not maintain if a transaction took place at an ATM at a grocery store or even another bank. However, there might be an assumption that, if questioned, you could identify the ATM where the transaction took place.

If you want some "authority" to point to, call the Helpline and see what they say, but the above is consistent with what they have told me in similar conversations.

The SAR was simply not designed to identify ATM locations, possibly due to the impossibility of doing so for foreign ATMs.