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#2267471 - 03/10/22 06:39 PM 2 CTRs - Same Transaction
Compliance NABW Offline
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Is there any prohibition against 2 separate institutions filing a CTR for the same transaction? So, let's say you have a customer at Bank A go into Bank B and use a Cash Advance Machine to withdraw $11,000 from their account at Bank A. For whatever reason, Bank A knows that actual cash was handed over to the customer. Bank B would file a CTR because they have a conductor taking $11,000 in cash. Does Bank A still file a CTR here, or because Bank B will file one, then they are absolved of doing so? It would still seem to hold that Bank A knows of a cash withdrawal occurring through their FI because they have the account from which the funds are withdrawn.

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#2267566 - 03/11/22 09:18 PM Re: 2 CTRs - Same Transaction Compliance NABW
Sunshine Lady Offline
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Bank A would file a CTR for the $11,000.00 cash advance and Bank B would file a CTR based on the cash deposit of $11,000.00. Neither bank is absolved of filing because of knowledge of where the funds came from.
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#2267577 - 03/12/22 04:52 PM Re: 2 CTRs - Same Transaction Compliance NABW
Amy S Offline
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I'm curious as to why Bank A would need to file if the cash transaction did not happen at one of their facilities. (my FI does not do cash advances, so I would not see this type of transaction) How would that be different than a customer taking a check from Bank A and cash it at Bank B? And how would you be able to fill out Part III Transaction Location?

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#2267593 - 03/14/22 02:46 PM Re: 2 CTRs - Same Transaction Compliance NABW
HappyGilmore Offline
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Pulling people out of the ditc...
I see no reason Bank A would file.

if a client has a check drawn on your bank, yet goes to another bank to cash it, the cash goes over the counter at the other bank, they would report, you would not. This is no different
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#2267594 - 03/14/22 03:12 PM Re: 2 CTRs - Same Transaction Compliance NABW
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,617
Galveston, TX
If Bank A is aware that the customer received cash - why would you treat it any different than a withdrawal at a foreign ATM. It would have to be aggregated with any other cash activity for that business day. Whether or not both Bank A and Bank B have to report the transaction or one of them would report for both of them, would come down to the network agreement.

That is how it worked years ago - has that changed?
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#2267623 - 03/14/22 07:36 PM Re: 2 CTRs - Same Transaction Compliance NABW
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Joined: Oct 2015
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@Happy and @Amy -- A check being cashed is not known cash coming out the deposit account at Bank A

@Sunshine - Bank B may or may not be having a deposit, but they have the conductor in person.

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