Here's the guidance from the CTR FAQ's:
27. When do you check the “Aggregated transactions†box (Item 24)?
Filers should check box 24e “Aggregated transactions†(along with any other box applicable in Item 24) only in the following circumstance: 1) the financial institution did not identify any of the individuals conducting the related transactions, 2) all of the transactions were below the reporting requirement, and 3) at least one of the aggregated transactions was a teller transaction. If the aggregated transactions being reported included only deposits made via a night depository, the financial institution would not check “Aggregated transactions†as none of the aggregated transactions were a teller transaction; instead, the financial institution would check Item 24 “Night Deposit.†A “teller transaction†would include, but would not be limited to: the deposit or withdrawal of currency by an individual at the teller window, an individual making a loan payment with currency at the teller window or, an individual exchanging currency at the teller window. The option “Aggregated transactions†is not the same as Item 3 “Multiple transactions,†which can involve transactions that are above the reporting requirement.
For example, if there were four $3,000 deposits made into ABC Restaurant’s business account in one business day, and the filing institution did not identify any of the individual transactors, and at least one of these deposits was made via a teller transaction, the filing institution would complete a Part I on ABC Restaurant checking Item 3 “Multiple transactions†and checking “Aggregated transactions†in Item 24.
However, if the filing institution identified the fourth individual transactor, as a result of knowing the transaction takes ABC Restaurant over the $10,000 threshold, then the filing institution would complete a Part I on ABC Restaurant checking Item 3 “Multiple transactions†and a separate Part I on the fourth individual transactor. The filing institution would NOT check “Aggregated transactions†in Item 24 due to the fact that it identified one of the transactors.
If there were four $3,000 deposits made into ABC Restaurant’s business account via any combination of Armored car (FI Contract), ATM, Mail Deposit or Shipment, or Night Deposit, i.e., without any of the deposits being made via a teller transaction, the Aggregated transactions box should not be checked. Instead, the other boxes in Item 24 should be checked to the extent that they are applicable.
The compressed version that I distribute to my CTR filers is:
1. Any transaction was over $10,000
2. At least one of the transactions was a teller transaction
3. The Bank was unable to identify the individual(s) conducting the related transactions
If those 3 criteria are met, then and only then would you use the aggregated box. From your circumstance I would need clarification regarding the night drop before making my judgment; was the $10,000 from the night drops in a single transaction, or multiple transactions? If there was a single night drop over $10k within that total, then you would not be able to use the aggregated box. If you have multiple night drops under the $10k mark and also have the currency exchanges that are under $10k which are teller transactions, you would use both the Night Drop and Aggregated boxes as far as I'm reading into it.
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