I'm working on a CTR and I'm arguing with myself, so I'd like other opinions please.
***I'm here before everyone else to get work done in peace, so I haven't had the opportunity yet to ask why we allowed this transaction to happen, but I expect the answer to be something along the lines of, "Because we're a community bank and the customer asked us to do that so of course we said yes."
John Doe and Jane Doe own a savings account.
Jane Doe called and requested a $10,000 cash withdrawal to be picked up by Anita Name.
An hour after picking up the $10,000 cash from Jane Doe's account, Anita Name came back to the Bank and withdrew $60 cash from her own account - thus she left the bank with $10,060 cash and a CTR is required.
I'm trying to decide if I should (absent discussing with branch personnel who have yet to arrive to shed light on the situation) complete Part I's for Jane Doe and John Doe. I can convince myself that Anita Name picked up $10,000 cash on their behalf - EVEN IF they were going to gift it to her simply because she saved them the trip to the bank to pick it up.
Normally on a cash out, I would - of course - only assign the cash to the person who picks it up (there would only be one Part I). However this feels like a unique case because a non-account owner with no signatory authority picked the money up.
But, I freely admit I might be thinking too hard about this.
On the other hand, when one person brings in 10 other persons' paychecks and a CTR is triggered, I follow the conservative path and complete 11 Part I's, so.....
As you can see, I've worked myself into a circle here. Any clarity will be greatly appreciated.
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