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#2073115 - 04/08/16 06:29 PM does virtual vault =teller transaction
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
For purposes of the CTR and determining whether you mark multiple transactions or aggregate transactions... does the fact that an armored courier pick up cash deposits and deliver them to a virtual vault count as a teller transaction.

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#2073119 - 04/08/16 06:37 PM Re: does virtual vault =teller transaction Chocaholic
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,722
Illinois
Multiple transactions are used any time there is more than one transaction involved for the person listed in Part I regardless of whether it is done at a teller, through a night drop or ATM or by courier.

It is not considered a teller transaction for the purposes of using aggregated transactions.

See FinCEN Guidance FIN 2013-R001 to see if you should check box 2d and entered the information regarding the armored car company into Part I or check the appropriate box in Item 24 for Armored Car (FI Contract).

https://www.fincen.gov/news_room/rp/rulings/html/FIN-2013-R001.html
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#2073129 - 04/08/16 06:49 PM Re: does virtual vault =teller transaction BrianC
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
thank you so much... I'm just wading through the bulletin now!

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