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#2242506 - 09/16/20 02:28 PM CTR Aggregated Question
Anonymous
Unregistered

You have ABC Mart bring in 4 transactions between 2 branches. First 2 transactions were for $950.00 a piece, although the teller knows (“identifies”) who made the transactions. Then two more people then go to another branch and make the other 2 transactions. One for $4,000.00 and one for $5,050.00 and the teller chooses the transactor for these transactions because they are over the cash limit we have set in our system. We now have a reportable CTR because they add up to over 10k. We have identified who made all the transactions because we saw them come in, but we did not id the transactors for the $950 transactions. When we do the CTR, do we have to list the transactors for those $950 transactions since we know them or can we use the Aggregated option and Multiple Transactions option and not list those two people?

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#2242511 - 09/16/20 02:50 PM Re: CTR Aggregated Question Anonymous
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
I believe that for situations like the one mentioned above you have the aggregated transactions box that you can select. Include all the transactions and the conductors that you do have but you will have a $950 transaction without a conductor.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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#2242517 - 09/16/20 03:40 PM Re: CTR Aggregated Question Anonymous
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The aggregated transactions box instructions in FinCEN's electronic filing requirement says:

Aggregate transactions (indicator). This element declares that the financial institution did not identify
any transactor(s) because the FinCEN CTR reports aggregated transactions all below the reporting
requirement with at least one transaction involving a teller.
“Aggregated transactions” is not the same
as “Multiple transactions,” which can involve transactions that are above the reporting requirement
where a transactor is known and may involve transactions none of which involved a teller.

Emphasis added.

"Did not identify any transactor(s)" indicates you would not check "aggregated transactions" if you have identified one or more of the transactors.

Yes on "multiple transactions."

You indicate the teller knows the transactors for the small deposits. They should be identified in the CTR. If you don't have all their info, you say so in the CTR.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#2242518 - 09/16/20 03:45 PM Re: CTR Aggregated Question Anonymous
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Those same instructions indicate your CTR will be accepted with a warning if there is a Part I section with item 2a, 2b, or 2d checked.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2242534 - 09/16/20 06:08 PM Re: CTR Aggregated Question Anonymous
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
Good catch John, yes select multiple transactions not aggregated transactions.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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