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#2170293 - 03/27/18 03:26 PM Collecting Info on all CTR Conductors
Bec Offline
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Bec
Joined: Jul 2010
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The Great White North
Scenario:
Accountholder has multiple locations and deposits regularly at different branches. Front line has been instructed to collect information on all conductors for that business regardless of transaction amount. For instance, there are five deposits performed by five separate conductors all under the amount of $3,000 however they aggregate to over the CTR reporting threshold. Since we collected the information, are we obligated to report all five conductors? If, as a matter of policy, we discontinue collecting information until the teller system prompts when exceeding the $10,000 limit are we able to just discontinue this arduous process?
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#2170295 - 03/27/18 03:30 PM Re: Collecting Info on all CTR Conductors Bec
ACBbank Offline
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New York City
I have not looked at a CTR in years, but isn't there a "Multiple Conductors" box?
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#2170342 - 03/27/18 04:36 PM Re: Collecting Info on all CTR Conductors Bec
thomasj Offline
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Pennsylvania
If you are collecting it, I would include it; however, you are not required to gather conductor information for transactions under $10k so you are going above and beyond. If all the transactions are under $10k you can rely on the "Multiple Transactions" reason for not listing a conductor/conductors. Keep in mind that if you have knowledge that one of the conductors has conducted multiple transactions over the $10k limit you do have to list them.

The tricky issue becomes explaining to an examiner why you changed the process. I'd be willing to guess that in many instances, institutions began collecting information from conductors below the $10k threshold due to pressure from examiners or auditors to do so as it was considered "Best Practice". So if you do decide to discontinue the practice, be prepared for that conversation.
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#2170393 - 03/27/18 06:13 PM Re: Collecting Info on all CTR Conductors Bec
Bec Offline
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Bec
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The Great White North
Yeah, good point. not sure if I want to open that can of worms and the front line is already accustomed to doing it. But I hate doing more than necessary because that can bite ya too.
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#2170528 - 03/28/18 01:07 PM Re: Collecting Info on all CTR Conductors Bec
Elwood P. Dowd Offline
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The only people who could tell you that you do not have to include information you actually possess work for FinCEN. Ask them, but I don't like your chances.
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