Thread Options
#2138521 - 07/18/17 01:33 PM Currency exchanges and CTRs
Nick Offline
New Poster
Joined: Mar 2017
Posts: 20
Hello All,

I looked through the forums and count not fund a specific topic on this scenario.

We have a bunch of businesses that exchange cash for coin or smaller bills when they make their regular deposits. I was wondering how other FI's do their CTRs when including currency exchanges. Do you include the amount of the change with the deposit amount in part 1 for both the business and the conductor (assuming that the currency exchanged was for the business)? Or do you just include the deposited amount in part I and then include the change in part II.

I look forward to seeing your responses!

Thanks!

Return to Top
BSA/AML/CIP/OFAC Forum
#2138528 - 07/18/17 02:10 PM Re: Currency exchanges and CTRs Nick
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Here is an example of what I think you are asking: On the same business day, a single individual acting on behalf of a corporation:

* deposits $8K in currency and
* does a $4K currency exchange.

Item 21 would be 12K and include the account number involved. Item 22 would be empty.

Item 25(a) would be 8K. Item 25(e) would be 4K. Total Cash In for Item 25 would be 12K.

There would be no entry in Item 27.

I cannot point you to any guidance on this point, but would simply say that this includes all possible necessary information and that no critic could point you to any guidance saying it's wrong. If you want assurance, call the Helpline.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#2138536 - 07/18/17 02:33 PM Re: Currency exchanges and CTRs Nick
Nick Offline
New Poster
Joined: Mar 2017
Posts: 20
That is how we do it. Thanks Ken!

Return to Top
#2142158 - 08/15/17 08:02 PM Re: Currency exchanges and CTRs Nick
ShaBanker80 Offline
New Poster
Joined: Apr 2017
Posts: 14
Another similar question regarding the change order combined with deposits.... Say all the cash deposits were through the night depository, but an individual came in to do a change order for the business... Would we NOT put an account number when filling in the information for the individual, since it was strictly a cash exchange and no account was technically involved?

Thank you for any input!

Return to Top
#2142188 - 08/15/17 10:45 PM Re: Currency exchanges and CTRs ShaBanker80
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
If the individual conducting the currency exchange is identified, his or her 2(b) entry would not contain an account number.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#2150097 - 10/17/17 04:09 PM Re: Currency exchanges and CTRs Nick
CML LHS Offline
New Poster
CML LHS
Joined: Oct 2014
Posts: 18
WA
To stem off of TexLaBanker, what if the cash exchange funds are in the night deposit bag? The cash exchange is completed by the teller at the same time that the night deposit is completed, and the change order is placed in the night deposit bag, and awaits pickup of the bags as usual. It has been our understanding that no individual conducted the transaction with the teller. And so we don't identify a conductor for these transactions. Is this accurate?

Additionally, our bank offers a "Day Drop" service for our night deposit customers. This means they don't have to drop the bags in the slot outside, but can walk into the open branch and drop the bags off with one of the tellers to be processed at some time during the business day. The customer/drop-off individual does not wait for the transaction to be completed, and the teller logs them as if they were in the night deposit. If the tellers are busy, they may not process the deposit until later that day. Then just as with night deposits, they put the receipt back into the night deposit bag and hold the bags for the customer to pick up later. Does anyone have input as to including these as "Night Deposit" transactions? Since the individual walked into the branch, does it count as a teller transaction, even if they do not stay and may not be the same person who picks up the bags and receipts?

We mark these transactions as night deposits, using the CTR FAQs #27: "If the aggregated transactions being reported included only deposits made via a night depository, the financial institution would not check “Aggregated transactions” as none of the aggregated transactions were a teller transaction; instead, the financial institution would check Item 24 “Night Deposit.” A “teller transaction” would include, but would not be limited to: the deposit or withdrawal of currency by an individual at the teller window, an individual making a loan payment with currency at the teller window or, an individual exchanging currency at the teller window."

Return to Top
#2150215 - 10/18/17 10:00 AM Re: Currency exchanges and CTRs CML LHS
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
l had to read the "currency exchange night deposit" a couple times to get the drift of it. The practice is outside my experience, but others may say it's common. You may not know who dropped off the night deposit, but you certainly know who picked up the credit side of the currency exchange and have no excuse for not including that person on the CTR.

As your question suggests you realize, your "day drop" transactions are not night deposits. Your bank is shielding them from scrutiny by classifying them as such. A reasonable reviewer would require you to go back and amend the CTRs to identify the person dropping off the bag.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#2150264 - 10/18/17 03:43 PM Re: Currency exchanges and CTRs Nick
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
As to the currency exchanges included in a night bag, it's usually the case that the only reason they are included on a CTR is that the total cash in amount includes one or more deposits in addition to the cash for the currency exchange.

For example, the bag's contents is one deposit that includes $5,000 in cash; a second deposit with $4,000 in cash; and a currency exchange of $2,000 in $100s to be exchanged for $2,000 in denominations of $20 or less. Total cash in amount is $11,000, Cash out amount will be $2,000. The "out" portion of the exchange is not reported. How would you connect the individual picking up the $2,000 in small bills to the "in" portions of the night deposit? I don't think you should. I'd use the "night deposit" excuse box and not include any conductor information.

I agree with Ken on the "day drop" piece of this question. Until FinCEN tells us that we can treat "day drops" as night drops and not report conductor information, I think that hiding behind the "night drop" excuse box is a violation.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2150584 - 10/20/17 08:37 AM Re: Currency exchanges and CTRs John Burnett
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
We'll disagree here. The bank is on notice that a CTR is required and, regardless of whether reporting the cash out is necessary, I'm going to identify the person who picks up the bag simply because I can.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z