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#2161626 - 01/24/18 02:23 PM CTR Exempt Customer
Jennifer Offline
100 Club
Joined: Dec 2014
Posts: 183
Two questions:

Same business owner makes deposits into two separate businesses - no co-mingling. Even though the businesses are not co-mingled, since the same person made both deposits - transactor - a CTR would have to be filed due to that fact, correct?

Second question - same scenario - pretending one of those businesses was CTR exempt - the bank would not report the CTR exempt customer, correct? The amount of the other business did exceed $10K.

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#2161628 - 01/24/18 02:29 PM Re: CTR Exempt Customer Jennifer
Cape Codder Offline
Gold Star
Joined: Jul 2011
Posts: 413
BSA gal - assuming the total cash in on your first scenario is over $10,000, yes, CTR reportable since you have a common conductor. You'll also have a CTR on the second scenario since the amount of cash to the non-exempt customer exceeded the threshold. You won't include the cash for the exempt customer in your CTR.
Nothing difficult is ever easy.

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#2161699 - 01/24/18 06:11 PM Re: CTR Exempt Customer Jennifer
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,268
Agree with Cape Codder.

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