I keep reading the CTR FAQ but can't clarify how the following situation should be handled:

Person comes into Branch 1 and deposits $2,500 into a business account.

Later that day, another person comes into Branch 2 and submits a series of deposits, each less than the reporting requirement, that brings the total deposits for the day over the $10,000.01 threshold. We have information on that second person to correlate to those transactions.

Since we don't have transactor information for the first person, do we identify this as an 'aggregated transaction', even though it was only one transaction?

Thanks.

Also, if in the example before-hand, if the other deposits were from a Common Carrier, would that sole transaction without an identified person also be marked 'aggregate'?

I'm probably overthinking this!

No. There are three requirements that must be met to use aggregated transactions.

1. At least one transaction be in person.
2. All transactions are less than $10,000
3. We do not identify any conductors.

In your example, although we are not required to identify the person who made the $2,500 deposit, since we identified the second person, we do not satisfy requirement 3 and do not check aggregated transactions.

Second example.

If the common carrier is contracted by the Bank and we check the box in Part II, then yes we would check aggregated transactions as well.

If the common carrier is contracted by the customer and we identify the carrier's business info in Part I, then we would not check aggregated transaction because again, requirement 3 is not met since we identified one conductor(the carrier) in Part I.

Brian...thanks so much...I was hoping that was the answer (the common carrier is contracted by the business)...Doug