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#2115182 - 01/23/17 08:03 PM Having Self-Doubt About CTRs and Exemptions
Wildcat Rampage Offline
Member
Joined: Aug 2016
Posts: 95
Kentucky - Home of the 8 time ...
I'm 99% certain that everything is kosher with the way we've been handling the situation on the accounts that I'm going to discuss, but I've talked myself into having some nagging doubt and I'd like a little clarification/reassurance if possible.

ABC, Inc. owns several Alice's Restaurant franchises. ABC, Inc. has opened 2 accounts with my institution - Account # 100001 , ABC, Inc. DBA AR # 1 and Account # 100002, ABC, Inc. DBA AR # 2. Every weekend the two restaurants deposit, in aggregate, a CTR reportable amount of cash. Here are my questions:
1) It was correct to aggregate these transactions for CTR purposes since they were on behalf of ABC, Inc., wasn't it?
2) Assuming that it was correct to aggregate the transactions made on behalf of ABC, Inc., and given that they're not ineligible for a Phase II exemption, the fact that the deposits are being aggregated from different physical locations doesn't make them ineligible for exemption, does it?
3) Assuming that all deposits were night deposits, should the CTR have had two Part I forms - one that read ABC, Inc. DBA AR # 1 - 123 Maple Street and another that read ABC, Inc. DBA AR # 2, 789 Oak Street?

Second situation.....

I'm reviewing my exemption list.

Damage, Inc. has been an exempt customer for many, many years. They have one account that reads Damage, Inc. DBA Orion # 1. I start to look for five transactions. I see that their three deposits come from three different stores (at least based on the different store numbers on the deposit tickets). They are all the same type of stores (Orion # 1, Orion # 2, and Orion # 3). Damage, Inc. has chosen to have these three retail outlets make deposits into the same account. I have asked my predecessor as BSA Officer if she can tell me where the stores are located and she doesn't know. Here is what I'm curious about:
1) Since all deposits are on behalf of Damage, Inc., they're still going to be eligible for exemption, aren't they? (This is similar to my question above.)
2) How much noise should I make to learn about the different store locations?

The account activity is reasonably mundane. It's cash-intensive, but expectedly so.

Thanks in advance for any advice and suggestions.
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#2115192 - 01/23/17 09:02 PM Re: Having Self-Doubt About CTRs and Exemptions Wildcat Rampage
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
1) Your customer has 2 accounts, each with a different DBA name, but all deposits are made on behalf of that customer and, if they are made on the same day and you know about them, they are subject to aggregation. Whether the funds came from one or more physical locations is irrelevant, but you must use one of the addresses that produced the cash today on today's CTR. You must list the different DBA's on the CTR, separated by a semi-colon in a single entry for the person on whose behalf the transaction is being conducted.

2) Same analysis as above, you only have one customer. The DOEP only has a place for one address. For due diligence purposes, I'll say you need to know all of the addresses, but you may use any of the addresses that produce the cash on the DOEP.

My observation that the address that produced the cash should drive the address used on either report came from ancient conversations with the Helpline. You are welcome to call and confirm it for yourself.
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#2115306 - 01/24/17 04:52 PM Re: Having Self-Doubt About CTRs and Exemptions Wildcat Rampage
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I started a response but saw that Ken's keyboard is faster than mine, so I will simply agree with Ken's analysis.
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#2115312 - 01/24/17 05:05 PM Re: Having Self-Doubt About CTRs and Exemptions Wildcat Rampage
Wildcat Rampage Offline
Member
Joined: Aug 2016
Posts: 95
Kentucky - Home of the 8 time ...
Thank you Ken and thank you John.
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