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#2256609 - 07/13/21 03:22 PM ATM Withdrawal
Luv2run Offline
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Good Morning,

I read an older thread about this and really am not sure where it all landed.....I had a customer come in and withdraw in person just under the threshold for a CTR to be needed. Earlier that day he had gone to an ATM (It was his debit card number) that does not belong to my bank and took out enough to throw him over 10K. I have knowledge of this final dollar amount from my cash report. Should I be filing a CTR even though that final withdrawal was not at any of our physical locations?
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#2256610 - 07/13/21 03:39 PM Re: ATM Withdrawal Luv2run
rlcarey Offline
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You have evidence that he walked away from your bank in one day with over $10,000 in cash. Yes - a CTR is required.
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#2256611 - 07/13/21 03:41 PM Re: ATM Withdrawal Luv2run
Luv2run Offline
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Thank you. My gut was telling me this, but that older thread had me second guessing. I always appreciate your help!
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#2256635 - 07/13/21 06:17 PM Re: ATM Withdrawal rlcarey
praBSA Offline
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Originally Posted by rlcarey
You have evidence that he walked away from your bank in one day with over $10,000 in cash. Yes - a CTR is required.

The OP said a different bank's ATM.

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#2256638 - 07/13/21 06:27 PM Re: ATM Withdrawal Luv2run
John Burnett Offline
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Let's rephrase it, then. If Luv2run's bank has knowledge its depositor received more than $10,000 cash from their account on the same business day via an in-person withdrawal and a nonproprietary ATM withdrawal, the bank needs to file a CTR.
Last edited by John Burnett; 07/13/21 06:28 PM.
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#2256641 - 07/13/21 07:10 PM Re: ATM Withdrawal Luv2run
praBSA Offline
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All that aside, would we file a CTR if we know? Yes, as John said.

It's a loaded question because, how do you even know the customer's transaction occurred today already? Did it post today? I am not sure of the size of your bank, but if you're setting the precedent you are going to actively look at customer's live card transactions the same day as a large cash withdrawal near the filing limit, you better start doing it for all customers.

I can't track all of my customer's live card transactions and look into each one. We go based on posted date otherwise we would have to find a way to integrate actual transaction card times with our transaction monitoring system and not just posted dates from our core. Seems like a slippery slope.

By that I mean, if my customer withdrew $9000 today and my customer withdrew $1500 from ATMs today from private ATMs, posting day would generally depend on the transaction time. My transaction monitoring system would have no way to know that a transaction that the $9000 cash withdrawal occurred the same day as $1500 in ATM withdrawals that posted 2 days later. I also don't know if it's customer A or customer B using customer A's card. Slippery slope. I never want to "assume" anything when reporting a transaction.

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#2256642 - 07/13/21 07:27 PM Re: ATM Withdrawal Luv2run
praBSA Offline
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Full disclosure, I deleted my prior response as to not confuse the OP.

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#2256650 - 07/13/21 08:50 PM Re: ATM Withdrawal Luv2run
Luv2run Offline
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I appreciate all the input! It sounds like we have a general consensus on the matter.
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#2256667 - 07/14/21 02:52 PM Re: ATM Withdrawal Luv2run
John Burnett Offline
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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.

It only makes sense that you'd do the same for any proprietary or nonproprietary ATM transaction.
Last edited by John Burnett; 07/14/21 03:00 PM.
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#2256685 - 07/14/21 05:07 PM Re: ATM Withdrawal Luv2run
praBSA Offline
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I am aware of that. What I'm saying is, it sets a bad precedent going out of your way to check for ATM transactions that haven't posted yet from a foreign ATM. Maybe I misunderstood the OP, sounded like the transactions had not posted yet. Of course if they posted the same day, a CTR should be filed. I would never go out of my way to assume that a transaction would post a particular day without it actually posting. It sounded like this was occurring in real time.

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#2256688 - 07/14/21 05:21 PM Re: ATM Withdrawal Luv2run
rlcarey Offline
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I think you are reading way too much into the original post. They said it appeared on their cash report. They were just asking whether or not, because it was at a non-proprietary ATM, did that impact reporting it.
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#2256694 - 07/14/21 06:16 PM Re: ATM Withdrawal Luv2run
praBSA Offline
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I was just initially thrown off by Randy's old advice from: https://www.bankersonline.com/forum/ubbthreads.php/topics/1438902/atm-withdrawals-ctr-reporting where he stated:

""The ATM withdrawals are from his account with us"

Unless he is getting the cash from the Bank's ATM, it would not be aggregated - he didn't get the cash from you."


--- Because of that, I started to read WAY to far into this question. Slippery slope haha

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#2256704 - 07/14/21 07:12 PM Re: ATM Withdrawal Luv2run
rlcarey Offline
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Yeah - that is also from 11 years ago and I think that if you read that entire thread that statement was pretty much overruled.
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