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#2128437 - 04/28/17 07:10 PM Official Check Payee & CTR reporting
jcampbell Offline
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Joined: Oct 2016
Posts: 1
Here's the scenario

We have a customer who came in and purchased an official check with cash payable to him and another individual.
Do we report the other individual on the CTR "for benefit of"?

These are the two ways I'm thinking of it:
1. No-For this specific transaction the cash was for benefit of the conductor and his purchase of a monetary instrument, regardless who the payee is.
2. Much like a deposit account, both him and this other individual now have access to the funds. If they were to deposit the cash into an account, we would report them both. So being they both now have access to these funds should we report them both here too?

Thanks in advance!

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#2128442 - 04/28/17 07:24 PM Re: Official Check Payee & CTR reporting jcampbell
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I'd go with option 1. The other guy isn't a "person on whose behalf" unless the remitter delivers the check to him. The remitter can still bring the check back unused and have it voided.
Last edited by John Burnett; 04/28/17 07:29 PM.
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