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#2067206 - 03/02/16 09:50 PM CTR Question-Cash Deposits of Joint Account Owners
Bonkers for BSA Offline
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Joined: Oct 2015
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John Doe, Mary Doe, and Jane Doe are the account owners of an personal account. John deposits $12K in cash into this account with the three owners and a CTR needs to be filed. I understand that the Bank needs to list John, Mary, and Jane as beneficiaries since they all have access to the funds. Do we need to have the occupation and driver's license of Mary and Jane to complete an accurate CTR? We collected John's at the time of the transaction.

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#2067208 - 03/02/16 09:56 PM Re: CTR Question-Cash Deposits of Joint Account Owners Bonkers for BSA
Elwood P. Dowd Offline
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If you don't have the remaining information for the other parties, then you just don't have it. (You were not required to get it as a condition of the transaction.) If the field for the missing information is "critical," click "Unknown." If it's not critical, leave it blank.

Personal observation, if I thought it would ever happen again, I might contact the other parties and try to obtain it or just ask them to give it to us the next time they are in because "we are updating our records." I would not mention the reportable transaction.
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#2067213 - 03/02/16 10:01 PM Re: CTR Question-Cash Deposits of Joint Account Owners Bonkers for BSA
edAudit Offline
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I understand that the Bank needs to list John, Mary, and Jane as beneficiaries since they all have access to the funds.

Just to clarify (Ken correct as usual) it is not that they have access to the funds but benefit from the transaction.
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#2067216 - 03/02/16 10:05 PM Re: CTR Question-Cash Deposits of Joint Account Owners Bonkers for BSA
Daisy Doodle Offline
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First, I would expect us to have all the account owner's info on file already (at least the DL--the conductor could probably supply the occupations for the other two). If we do not, we would contact the branch and require them to make a good faith effort to obtain the missing info. If we could not easily get it in a few days, we would file 'unknown'. But we try to get it. And remind the tellers they should have gotten all the needed info (or at least known they needed it and have addressed it with the customer already) at the time of the transaction, even if it was inconvenient for all.

Also, with 3 owners on the account and a larger cash deposit I would also be checking the account to see if this was isolated, or if we have a 'hidden business'. I always wonder when multiple owners and larger transactions present themselves together.

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#2067221 - 03/02/16 10:13 PM Re: CTR Question-Cash Deposits of Joint Account Owners Bonkers for BSA
Daisy Doodle Offline
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Southern U.S.
I know you can file 'Unknown'. But we don't often let up on our tellers and branches over CTR's...and because we are fairly relentless we have a moderate number of these situations. I think they would be common if we were relaxed about it.

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#2067227 - 03/02/16 10:25 PM Re: CTR Question-Cash Deposits of Joint Account Owners Bonkers for BSA
Hogfan5 Offline
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Would you not have gotten that information for Mary and Jane at account opening?

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#2067228 - 03/02/16 10:29 PM Re: CTR Question-Cash Deposits of Joint Account Owners Hogfan5
Elwood P. Dowd Offline
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After October 1, 2003, certainly. Before then it was hit or miss. It varied wildly between banks and perhaps even more wildly between branches of the same bank.

It was the CIP reg that homogenized the process. Some banks have accounts that are 30 - 50 years old on which they have no identifying information. For some, getting a TIN on every customer was a long term project.
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#2067230 - 03/02/16 10:32 PM Re: CTR Question-Cash Deposits of Joint Account Owners Elwood P. Dowd
Hogfan5 Offline
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Being at a bank that opened in 2005, I just assumed and look where it got me!! Shocking. HAHA I should know better then to assume....

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#2067325 - 03/03/16 04:52 PM Re: CTR Question-Cash Deposits of Joint Account Owners Bonkers for BSA
Bonkers for BSA Offline
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Joined: Oct 2015
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This account was pre-CIP/Patriot Act and we don't have DL information. We've reviewed the statements to see if there was any direct deposits where we could try to figure out where Mary and Jane work.

Our plan right now is to reach out to the customer to see what information we can get.

Thank you, all.

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#2214897 - 06/04/19 04:46 PM Re: CTR Question-Cash Deposits of Joint Account Owners Bonkers for BSA
MBTCompliance Offline
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Conductor A brings in $20,000... $13,000 for Entity, $7,000 for Beneficiary A who is a co-borrower on a loan with him

Conductor A is listed on the CTR for $20,000

Entity is listed on the CTR for $13,000

Beneficiary A is listed on the CTR for $7,000

Wife of Beneficiary A made a deposit to their joint personal checking account for $1,000 on the same day. Do we now list that on the CTR, making Beneficiary A's total on the CTR $8,000, and do we also add wife as Conductor B for $1,000?

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#2214901 - 06/04/19 05:19 PM Re: CTR Question-Cash Deposits of Joint Account Owners Bonkers for BSA
John Burnett Offline
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Beneficiary A is not a person on whose behalf more than $10,000 in cash transactions were conducted on that day. You had to identify Beneficiary A as a person on whose behalf the $7,000 was paid on the loan.

But the $1,000 deposit by Beneficiary A's wife doesn't get included because it only brings Beneficiary A's aggregate amount to $8,000. If that deposit had been for $4,000, it would have made Beneficiary A's total $11K, and it would have been reportable by adding his wife as a conductor and adding the account number and $4.000 amount to Beneficiary A's info in the combined CTR.
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