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#2261900 - 11/01/21 04:51 PM Cash Never Left Bank, CTR Required?
fiauditor2021 Offline
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A customer comes in and withdrawals over $10,000 from their deposit account. They then immediately go to the loan window and use the cash to make a loan payment. Is a CTR required since the cash never left the Bank?

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#2261908 - 11/01/21 05:44 PM Re: Cash Never Left Bank, CTR Required? fiauditor2021
ACBbank Offline
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Did they receive the physical currency?
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#2261916 - 11/01/21 06:31 PM Re: Cash Never Left Bank, CTR Required? fiauditor2021
HappyGilmore Offline
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Pulling people out of the ditc...
customer makes a withdrawal over $10k and is given cash...customer takes this cash and goes to loan department and makes loan payment with same cash of over $10k...

yep, CTR all day long in my book. customer was given and took possession of cash...
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#2261918 - 11/01/21 06:46 PM Re: Cash Never Left Bank, CTR Required? fiauditor2021
rlcarey Online
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"Same cash" - even if you knew that to be the case, they took possession of the currency. I agree - reportable twice.
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#2261954 - 11/01/21 11:02 PM Re: Cash Never Left Bank, CTR Required? fiauditor2021
Richard Insley Offline
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Toano, VA
This is one of those unusual cases where form trumps substance. Debiting a deposit account and offsetting that debit with a credit to loans is not reportable...but that's not what happened. Instead, the customer chose (for what reason?) to complicate things. When teller A counted out $10K+ and handed it to the customer, a reportable currency transaction occurred. The subsequent transaction (loan payment) can't unring the first CTR bell, and the cash payment on the loan is a second CTR bell.
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#2261969 - 11/02/21 02:22 PM Re: Cash Never Left Bank, CTR Required? fiauditor2021
ACBbank Offline
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If what Richard said is accurate a CTR is warranted. Why a simple debit and credit transaction wasn't performed is a good question.
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#2261973 - 11/02/21 03:45 PM Re: Cash Never Left Bank, CTR Required? fiauditor2021
Sheba Offline
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Oz
As a follow-up to the responses to this question, would you treat this differently if both transactions were done at the same teller window. For example, Customer asked for and received the cash over $10k. Did not leave the teller window, but once the cash was counted out to him requested to make a loan payment with the entire amount. The teller made the loan payment and took all of the cash back. The teller has processed a cash out of over $10K and then a cash in of over $10K. Is a CTR needed in this situation?

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#2262022 - 11/02/21 09:10 PM Re: Cash Never Left Bank, CTR Required? Sheba
Richard Insley Offline
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Toano, VA
Originally Posted by Sheba
Is a CTR needed in this situation?
The safest answer is "no", because that's what your books will reflect a year from now if your regulator happens to look back at these transactions.

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#2262040 - 11/03/21 01:40 PM Re: Cash Never Left Bank, CTR Required? fiauditor2021
John Burnett Offline
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Cape Cod
I agree. The fact that the cash crossed the teller window and was in the customer's possession completes the cash-out transaction. When the cash crossed the teller window the second time, it's a separate transaction (cash-in) once it's back in the hands of the bank, even if it's clearly the same physical cash. Report both transactions on your CTR.

Would it have been more efficient to simply debit the deposit account and credit the loan account, so that no cash is involved? Of course it would. But that's not what happened.
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#2262169 - 11/05/21 02:41 PM Re: Cash Never Left Bank, CTR Required? John Burnett
Sheba Offline
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Sheba
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Oz
Thanks for the responses Richard and John. As our system shows the time and teller and we could always verify that cash never left the building but had remained in front of the teller, we were not filing on these rare events. However based on these discussions I will update our procedures and begin filing CTRs for these situations when they occur. Thanks again for your insight.

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