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#2174971 - 04/24/18 07:47 PM CTR Persons Involved?
JillR Offline
New Poster
Joined: Jun 2013
Posts: 18
Omaha, NE
I think I'm over (or under?) thinking this CTR and confusing myself, so I hope someone can set me straight!
Customer A is a joint owner on 2 accounts. She makes a $24,300 cash deposit to account #1 which is joint with customer B and customer C. She also makes a $1300 cash deposit to account #2 which is joint with customer D. So we have a multiple Part 1 CTR: $25,600 for customer A; $24,300 for customers B and C. My question is, would customer D be included on the CTR, since the only cash benefit she saw was the $1300?

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#2174999 - 04/24/18 09:09 PM Re: CTR Persons Involved? JillR
bcompliance Offline
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Joined: Sep 2014
Posts: 1,228
Yes. Review the CTR FAQs found here: https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr . There is one that addresses this scneario (I can't remember which one and didn't have time to look it up)
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#2175011 - 04/24/18 10:25 PM Re: CTR Persons Involved? JillR
JillR Offline
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Joined: Jun 2013
Posts: 18
Omaha, NE
I did read through the FAQs - must have missed this scenario. I'll read through them again. Thanks.

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#2175015 - 04/24/18 11:04 PM Re: CTR Persons Involved? JillR
BuckDog Offline
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Joined: Jun 2006
Posts: 123
Tennessee
All persons benefiting from the cash deposits with their information would be included on the CTR as well as the person conducting the transactions. In the case of the conductor, the box would be marked "conducted on own behalf". All the rest would have the box marked "Benefited from the transactions".

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#2175260 - 04/25/18 08:46 PM Re: CTR Persons Involved? JillR
bcompliance Offline
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Joined: Sep 2014
Posts: 1,228
Here is a similar thread: https://www.bankersonline.com/forum/ubbthreads.php/topics/2123043/ctr-question

Look at question #17 of the FAQs.
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#2175345 - 04/26/18 03:34 PM Re: CTR Persons Involved? JillR
JillR Offline
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Joined: Jun 2013
Posts: 18
Omaha, NE
Thank you so much - I was definitely "under-thinking" on this one!

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