Our examiners told us that for CTR activity, we should always look at the source of the funds.

So if our system requires that the check be deposited first and then cash w/d, then we list it as a negotiable item that was cashed.

In this particular transaction, the customer obtained a loan. The loan funds were advanced to his checking. He made the w/d from his checking. The checking account number ties the actual cash out to the transaction. But, according to the examiners, we need to indicate that this was (b)-- credit advancement. There is no way to fully link the transactions without listing the loan and the checking account, but then it looks like it was multiple transactions. And while that is true, these were not multiple cash transactions, so we wouldn't select multiple cash transactions.

How do I fill this out correctly?

The source for both transactions is the checking account. Your examiners are wrong. Whether they deposited the check into their account today or 10 days ago, the cash came from their checking account.

Randy is correct. The cash came from the checking account, not the loan advance. You don't count electronically moved funds for a "Currency" transaction report.

So the issue that we have (and probably why the examiner is citing you) is FAQ #30 which requires that we identify the purchase of a negotiable instrument if it occurs at the same time as a cash deposit to a checking account followed by a purchase of a negotiable instrument over $10,000. It is not that much of leap to apply the same logic to a loan advance.

Related Thread

Original Anon here. The other issue we have is the CTR User Guide, which states: use the options provided that “best describe the transaction or aggregated transaction.”

The guide doesn't indicate which acct number we would use.

In my mind, I agree with Randy. It seems illogical to provide the loan number. But, when you think through BrianC's example above-- then it does seem like you could make the leap that the funds came from the loan advance.

We have been cited on this in the past and it has been an audit finding, so we want to ensure we are getting it right. I know I can call FinCEN, but it seems like that doesn't always hold up either.

Maybe we should just make a decision and stick with it?