Hello,

We have always included joint account holders when doing a CTR for cash withdrawals. With that being said, If a one account holders (person A) comes in and withdrawals $20,000 and then during the same day the other account holder (person B) comes in and withdrawals $100 cash out of an account that only has his name on it, would that cash withdrawal by person B be included on the CTR? If going by my initial thought I was going to file the CTR as:

Part I: Person A, Conducting transaction on own behalf - $20,000
Part I: Person B, Conducting transaction on own behalf- $20,100

Does that work?

If I were including a joint owner on the CTR for withdrawals, I'd file it as you indicated in this scenario.

If you are assuming that Person B benefitted from the $20,000 withdrawn by Person A, why do you not make the same assumption about Person A benefitting from the $100 withdrawn by Person B.

FAQ #24 put out by FinCEN is pretty specific about only including joint owners on withdrawals if the institution HAS knowledge that the individual not present will benefit from the transaction.

I would re-examine why joint owners are being included on the CTR in the first place.

I almost posted the same, but look at the OP carefully. The $100 withdrawal was from an individual account.

I back what TXBSA said. I would not include the joint owner simply because they are a joint owner. Our front line staff are trained and hopefully ask questions to determine how the money will be used. If Person A takes 20,000 and goes on a weekend retreat that Person B does not get to go on it seems that there is no reason for Person B to be on a CTR.

BrianC great observation per usual. I missed it after first read.

I missed that as well. Sorry about that! If you are going to include the joint owner then your original thought would be correct.

Definitely living the fun life! One heck of a retreat.