Banks complete cash deposits conducted by third-party non-signers all the time. Consider how many of your business customers send an employee who doesn't sign on the customer account with their daily deposit. But regardless of what your policy on that question is, if it happens, here's what the CTR should look like:
Last edited by John Burnett; 12/23/20 03:20 PM. Reason: additional info
If the bank knows that a CTR is required when the third party makes the deposit (e.g., the deposit includes more than $10,000 in cash or a system prompt on the teller terminal notifying that the cash amount in the current deposit takes the aggregate cash-in amounts over $10,000 on the current business day), the bank will need to obtain personal info from the third-party to complete a Part I entry for them as a conductor.
If the bank is not aware of the fact that the deposit will make a CTR necessary when the transaction is completed (typically they learn the CTR is needed the next day when cash aggregation reports provide that information), and the bank is not aware of any conductor names, it will check the "aggregated transactions excuse box" in item 24 of Part II to indicate that at least one of the transactions was processed by a teller, and that none of the transactions included a reportable cash amount by itself. And there will not be a Part I entry for a conductor.
Note, though, that if the bank does know one conductor of the deposits included on the CTR, that conductor will be reported in a Part I section (box 2a checked), and the aggregated transactions box in Part II should NOT be checked.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8