I've researched this scenario on this forum and I haven't seen this explicitly spelled out (or at least I missed it), and I want to be certain that I have it down before I present training. So here goes.

Bill and Ted received a $15,000 check made payable to Bill Preston, Esq. AND Ted Logan. They go to the bank together to cash the check. Since they're together and the check is "AND", the CTR needs to have a "Part I" for both of them - with "Box A" being the one who handed the check over and received the cash and "Box C" for the other one. Is that right?

On the other hand, if Beavis comes to the bank with a $15,000 check made payable to Beavis AND Butthead, but Beavis is by himself, and the bank cashes the check that Beavis presents (forgetting discussions of proper endorsement, witnessing, etc.) - the consensus of what I have read here is that the CTR need only reflect Beavis. Is that also correct?

Lastly, if Thelma and Louise come to the bank with a $15,000 check made payable to Thelma OR Louise and Louise endorses the check, but Thelma hands the check to the teller and receives the cash would the CTR: a) Be completed for Louise only; b) Be completed for Thelma only; or c) be completed with "Box B" for Thelma and "Box C" for Louise.

Tangent - If Louise endorsed the check, but Thelma brought it in by herself, which of the above would be correct?

Thanks in advance, I'm trying to get my ducks in a row before someone throws out a question for me at training.

Nearly 100 “views” and no responses... I think you cut down your list of possible respondents because one of the answers would be “none of the above.”

If a check is payable to two people; i.e. the conjunction between their names is “and,” the teller should obtain identification from both, record it, and watch both sign or have each confirm any previously affixed signature. (If it helps, pretend every such check is a Treasury check.) So, your second scenario is out. (I would not fire a teller for making a mistake on a CTR. I would definitely fire a teller for cashing a check requiring two signatures without following the ritual.) A supervisor might override the need for the ritual. My displeasure would only accrue if the bank lost money because of the supervisor's decision.

If the ritual is followed, the CTR would indicate that each payee was acting on his own behalf and include all necessary information.

If the conjunction is “or,” there is no ritual; either endorsement will suffice and the identification required would be that of the sole endorser. There is no guidance about how to fill out the CTR. To me, it's analogous to a withdrawal from a bank account, if you have no idea whether the other payees benefitted from the encashment, list only the person across the counter and indicate that he or she acted on their own behalf. Choosing the “optional” approach applicable to withdrawals, I personally would choose to list the other payees as persons on whose behalf the transaction was conducted and include as much information as I had, even if it was only their names.

Thank you Ken - really appreciate the feedback.

"Tangent - If Louise endorsed the check, but Thelma brought it in by herself, which of the above would be correct?"

First, I'd have Thelma indorse the check if she's going to cash it. Then I'd ask her if she's acting on her own behalf (she's going to keep all the money), on behalf of Louise (she's going to give all the money to Louise) or on behalf of Louise and herself (they're going to split the dough somehow). Complete the CTR accordingly.

BUMP - for a special situation.

I think I know the answer, but I have a sinus infection, I've been out two days, I have examiners, and my brain is scrambled.

Bill and Ted came in to the Bank together. with two checks made to Bill AND Ted in the amount of $9,000.

Both checks were properly endorsed.

Bill handed check # 1 to the teller and was handed $9,000.

Ted handed check # 2 to the teller and was handed $9,000.

Bill walked out with $9,000, Ted walked out with $9,000.

I think I don't have a CTR. At best I think I have potential structuring. The person who was steering the ship in my absence created a CTR for this incident because they came in together. I don't think that's appropriate, am I right or is that the sinus medicine talking?

It is the sinus medicine...

They both received the benefit of $18,000 so a CTR is needed.

Here is my quandary from a practical standpoint.

Bill and Ted were cashing an on-us check.

They came in at the same time. The teller who cashed the checks was not paying much attention and didn't prompt a system CTR, so Bill and Ted left the bank without giving us their SSNs. How hard am I going to be kicked for filing a CTR without that information?

Probably won't be kicked too hard if at all especially if you document this, provide training to your tellers (document it) and don't let it happen again.

Thank you.

They JUST had training. Literally. Two weeks ago.

Don't feel too bad. I had just done training at all our branches and the next week I had a teller totally do something that I had just trained on and was very specific about during the training. I have decided we don't have a training problem, they have a learning problem.

And if the two $9,000 checks were received from the same maker, especially if issued in consecutive order, you've got a third player for your SAR.

I haven't considered the third player for the SAR. That was Dewey, Cheatum, and Howe Attorneys at Law. I felt that they were simply disbursing funds to Bill and Ted as requested.

However, I have another thing that is making me really doubt the benefit of sinus medicine this morning.

John Doe made two deposits yesterday. He deposited $5,000 cash into the Doe Enterprises, LLC account. He also deposited $7,000 into the John and Jane Doe personal account.

I know I need two Part I's - Doe Enterprises and John Doe. I'm 50/50 on Jane Doe. She received benefit of $7,000 that John deposited, but that's not over $10,000 (but neither was Doe Enterprises, but it was integral in John Doe's CTR). I hate taking medicine and dealing with time change and doubting myself and having examples that don't go into actually complex situations that bankers face.

Jane doesn't get included in the CTR. She is not a person on whose behalf more than $10,000 in reportable cash transactions was conducted. Sinus medicine or not.

With some gentle prodding, I'm recanting that. John is a 2a, and both the business and Jane are 2c entries.

Thank you John. I eventually talked myself into that conclusion as well.

I'll stick by my guns that I wish the examples from FinCEN would be more complex and more like what we actually see.