Good morning - I have a quick question. If a counter withdrawal slip is cashed from the account of a legal entity account is the CTR completed on the entity and the person taking the cash as the conductor or only on the person taking the cash as on their own behalf? This is a withdrawal from the account and not a check.

Please any help or guidance would be greatly appreciated as I'm new to the bank and have a meeting to discuss this later today with upper management.

One of many Related Threads

Thank you for the response but I don't think this answers my question. In the examples of the attached it discusses cashing checks and a check is a negotiable instrument made payable to someone...in my question this is Bank counter item w/d slip where funds are withdrawn from the entities account - a w/d slip is not a negotiable instrument paid to a specific person.

So if I have a transaction that is a withdrawal from a legal entity account (transacted with a w/d slip NOT a check) would the CTR be 1 page for business where funds were taken from and 1 page for person conducting the transaction or would a CTR with only 1 page for the person withdrawing the funds be okay as conducted on own behalf?

Hello, hopefully this helps more: https://www.bankersonline.com/qa/how-fill-out-ctr-businesssigner

Also from BrianC in that thread:

There is person conducting the transaction and person on whose behalf a transaction is conducted. The question is, "Did the person making the withdrawal conduct the transaction on behalf of the business."

"In Randy's example, if I am cashing a paycheck, then I am cashing the check on my own behalf and that's it. FAQ #24 introduces the concept of "knowledge" for withdrawals from a joint account. Although a business account is not a joint account, if we have knowledge that a withdrawal is conducted on the business' behalf to purchase equipment, for petty cash, to fund and ATM, etc. then it is appropriate to identify the person making the withdrawal as "conducted on behalf of another" and the business as "person on whose behalf the transaction is conducted."

I agree with the FDIC that if we have knowledge, the business should be included."


Basically, does your institution have knowledge that the withdrawal was conducted on behalf on the business?

Correct, Texibus.

Whether a negotiable instrument or withdrawal slip is used only impacts what line the dollar amount is listed in Part II. The persons listed in part I are based on the bank's knowledge of the purpose of the transaction.