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#2095445 - 08/26/16 01:31 PM Aggregation - Asking the Obvious w/ CTR Reporting
Wildcat Rampage Offline
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Joined: Aug 2016
Posts: 91
Kentucky - Home of the 8 time ...
I hate to toss out a softball, but my hand is being forced based on my research and recent move to the BSA/AML seat. I have experience with BSA, but haven't been actively around it in about five years or so.

Apologies made, I am 99.999% certain that I am right with my understanding of aggregation, but my predecessor - who is transitioning duties to me - believe differently and is causing me to wonder if I'm wrong. So, here goes:

To simplify I look at the requirement to file a CTR due to aggregation as boiling down to one of two things:
-Beneficial Ownership, or
- The person conducting the transaction

As an example of beneficial ownership

John Doe DBA Doe's Tree service - John Doe's son deposits $7,000 cash for his father
John Doe & Jane Doe joint account - Jane Doe deposits $4,000 cash into the joint account

These happened on the same business day.

In terms of beneficial ownership John Doe had $11,000 deposits into his accounts and a CTR is required, even though he didn't appear at the bank. The persons conducting the transactions will need to appear, etc but...

An example of the person conducting the transaction.

Yogi Bear is an entrepreneur. He has three companies - LLC 1, LLC 2, and LLC 3.

Yogi brings in the deposits for each company every day because he's a hard worker.

He deposits cash in the amount of $5,000 for LLC 1, $4,000 for LLC 2, and $3,000 for LLC 3.

Because Yogi brought in $12,000 in cash we do a CTR indicating that he brought in $12,000 in cash. Because of the electronic forms, we would go so far as to indicate the specifics for LLC 1, 2, and 3 but we don't really file on them since they're not comingled, etc. as I've seen in the other threads that stem from an advisory letter.

So, am I right in the above scenarios about my need to file CTRs? I feel that these are obvious, but given the lack of agreement and the lack of an example specifically like these scenarios I have just a little uncertainty about them.

Thanks in advance.

Last edited by Wildcat Rampage; 08/26/16 01:32 PM.
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#2095461 - 08/26/16 02:35 PM Re: Aggregation - Asking the Obvious w/ CTR Reporting Wildcat Rampage
PrimeTime Offline
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Joined: Nov 2014
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If I'm reading the above correctly, you would be filing in both scenarios.

Scenario 1 would list $11,000 for John Doe with 2c checked off (Person on whose behalf transaction was conducted, as he's the beneficiary of all transactions), $7,000 for Son Doe with 2b checked (Person conducting transaction for another), and $4,000 for Jane Doe with 2a checked off (Person conducting transaction on own behalf). This CTR is filed on the basis of John Doe as a common owner of the accounts.

Assuming the LLC's in Scenario 2 are independent of each other-- it would list $12,000 for Yogi Bear with 2b checked off (Person conducting transaction for another, assuming it's not Yogi Bear dba LLC), and then each of the LLC's with their individual amount with 2c (Person on whose behalf transaction was conducted. This CTR would be filed on the basis of Yogi Bear as the common conductor; I think that's what you were referring to when you stated that you wouldn't really file on the LLC's since they're not comingled, right? Because you're absolutely including their information in the CTR, it's just that had there been 3 separate conductors there would be no filing.
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#2095464 - 08/26/16 02:43 PM Re: Aggregation - Asking the Obvious w/ CTR Reporting Wildcat Rampage
BrianC Offline
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Joined: Nov 2004
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Illinois
CTR aggregation rules state that a CTR is required if more than $10,000 in cash in deposited by or on behalf of a single entity. In your first example, more than $10,000 was deposited on behalf of John Doe. Consequently you have three part I's.

John Doe - box 2c transactions conducted on his behalf. Also check Multiple transactions since there were two deposits to his accounts. List $11,000 for John and both accounts.

John's son - box 2b transactions conducted on behalf of another. Do not check multiple transactions. He only made one deposit. Only list the D/B/A account and $7,000 for junior.

Jane - box 2a transactions conducted on own behalf since she is an owner of the joint account. Do not check multiple transactions. Only list the joint account and $4,000.

Second example. These transactions must be aggregated since they were performed by the same person. There will be 4 part I's. Yogi - box 2b transactions conducted on behalf of another (the three LLCs). Check box 3 since there were three deposits. List all accounts and $12,000.00

For each LLC - box 2c transactions conducted on their behalf. Do not check box 3 since they each only had one transaction. List only the LLCs account number and appropriate dollar amount of the deposit for each.

John & Ken, I passed my CAMS this month. Did I get this test question right, too? smile
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#2095512 - 08/26/16 03:56 PM Re: Aggregation - Asking the Obvious w/ CTR Reporting Wildcat Rampage
Wildcat Rampage Offline
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Joined: Aug 2016
Posts: 91
Kentucky - Home of the 8 time ...
Thank you both - I was going to file on both and do it as both of you prescribed ,but it's good to get the feedback/reassurance.
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#2095640 - 08/26/16 09:13 PM Re: Aggregation - Asking the Obvious w/ CTR Reporting Wildcat Rampage
John Burnett Offline
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Cape Cod
Congrats on the CAMS, Brian. And you nailed it.
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