praBSA -- It's an established rule that CTRs are based on transactions posting on a given business day, not on when the customer actually made the transaction. For example, if your bank posts transactions to accounts only on weekdays but you are open for business after cutoff on Friday and on part of Saturday, the after-hours Friday transaction and the Saturday transactions post on Monday (assuming it's a business day), and you'd aggregate any cash activity that posted on Monday to determine whether to file a CTR and for what amounts.
Last edited by John Burnett; 07/14/21 03:00 PM.
It only makes sense that you'd do the same for any proprietary or nonproprietary ATM transaction.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8