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#2254371 - 05/25/21 05:12 PM What Transactions to include on CTR
Couples Offline
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Joined: Apr 2009
Posts: 280
The Igloo
We have a business customer M M, Inc that $8,201 in cash was deposited into account #123 via night drop yesterday. Then Jane came to the bank yesterday and deposited $1950.00 into M M, Inc.'s account #123.

Yesterday Jane also deposited $3855 into McDee's Drive-thru account #999. McDee's Drive-thru account #999 is a sole-proprietor account dba McDee's Drive-thru of which Jane is a signer.

We know a CTR is required for M M, Inc. in the amount of $10,151 which includes the night drop deposits ($8201) and Jane's deposit ($1950). Jane will be included on the CTR as Part 2 - conducted on behalf of another person for her $1950 deposit into M M Inc's account.

My question is would the $3855 that Jane deposited into McDee's Drive-Thru's account #999 be included in Jane's portion of the CTR for M M Inc.

Thanks! I hope I made this clear!

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#2254373 - 05/25/21 05:26 PM Re: What Transactions to include on CTR Couples
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
Since Jane did not deposit more than $10,000 and McDee did not have more than $10,000 deposited on its behalf, the $3,855 would not be aggregated for this CTR.
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#2254376 - 05/25/21 05:48 PM Re: What Transactions to include on CTR Couples
Couples Offline
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Posts: 280
The Igloo
That was my initial thought also so I reached out to a Compliance Firm we use and they said it would be aggregated and this is the quote "The requirement is that "All the individual transactions a financial institution has knowledge of being conducted by or on behalf of the same person during a single business day must be aggregated". However, it seems like they missed the over $10,000.

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#2254378 - 05/25/21 05:56 PM Re: What Transactions to include on CTR Couples
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
They state the correct requirement, but I agree they didn't apply it correctly. In your scenario, we had $10,151 on behalf of M M so those are the transactions that are subject to aggregation.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

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#2254379 - 05/25/21 05:56 PM Re: What Transactions to include on CTR Couples
Couples Offline
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Joined: Apr 2009
Posts: 280
The Igloo
That is what I thought! Thanks for your help!

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