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#2268643 - 04/04/22 04:53 PM CTR Help!
Pepperjam_184515 Offline
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Joined: May 2017
Posts: 12
Hello All!

I have a question regarding the following scenario for a CTR - and I just want to make sure I am understanding this correctly.

Jill came into the bank (alone) to deposit an even $10,000.00 to an account with her and her husband, Jack, listed as joint owners.

A little while later, Jack came into the bank (alone) to deposit an additional $12,000.00 into the same bank account as listed above.

Would I do the CTR as follows:

*Part I Person - Jill - as 2A selected and 3 checked and $10,000.00 in #21
*Part I Person - Jill as 2C selected and 3 checked and $12,000.00 in #21
*Part I Person - Jack as 2A selected and 3 checked and $12,000.00 in #21
*Part I Person - Jack as 2C selected and 3 checked with $10,000.00 in #21

Am I thinking correctly that I would do each Part I as described as above?

Of course, any help is appreciated!

Thanks!

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#2268644 - 04/04/22 05:10 PM Re: CTR Help! Pepperjam_184515
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,240
Illinois
FinCEN CTR FAQ #23 agrees with you.
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#2268649 - 04/04/22 06:12 PM Re: CTR Help! Pepperjam_184515
SmallBankBSA Offline
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Joined: May 2018
Posts: 147
am I overthinking? would there be a 2B for both Jack and Jill- person conducting transaction for another? I completely may be overthinking this scenario as we are in "EXAM" mode and I'm second third and quadruple guessing every move I made over the course of the last year!


Jill - 2A -person conducting transaction on own behalf $10,000
Jill - 2B - person conducting transaction for another $10,000
Jill 2C - person on whose behalf transaction is conducted - $12,000

Jack - 2A - person conducting transaction on own behalf $12,000
Jack 2B - person conducting transaction for another $12,000
Jack 2C - person on whose behalf transaction is conducted - $10,000

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#2268650 - 04/04/22 06:31 PM Re: CTR Help! Pepperjam_184515
Pepperjam_184515 Offline
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Joined: May 2017
Posts: 12
Brian C - Thank you for the clarification. It's not very often I have these scenerio's as usually there is only 1 transaction on a joint account that only 1 Part I would apply for each joint owner. smile

SmallBankBSA - I was thinking of that too - but I wasn't sure if that scenario applies as both Jack and Jill are on the account. If I'm thinking correctly, that scenario would apply if someone that wasn't on the account, came to deposit funds into their account.

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#2268651 - 04/04/22 07:01 PM Re: CTR Help! Pepperjam_184515
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,240
Illinois
The FAQ that I linked to above makes it clear that we would not use 2b since both individuals made deposits to the account on which they were an owner. This scenario has four Part I's, two for each owner, not three.
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#2268665 - 04/05/22 11:41 AM Re: CTR Help! Pepperjam_184515
SteveDave Offline
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Joined: Aug 2021
Posts: 62
I agree with BrianC. The FAQ is how I would file.

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#2268667 - 04/05/22 01:20 PM Re: CTR Help! Pepperjam_184515
Pepperjam_184515 Offline
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Joined: May 2017
Posts: 12
Thank you all for your help! Totally Appreciated! smile

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#2268681 - 04/05/22 03:39 PM Re: CTR Help! Pepperjam_184515
Susielou Offline
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Joined: Aug 2005
Posts: 337
Midwest
I also have a question along these lines. Jack deposits $52,000 into joint account with Jill. Jack then purchases a Cashiers check for $51,000. Daughter Judy deposits $500 into her account on which Jill is a joint owner.

Part 1 Jack 2A person conducting transaction on own behalf $52,000
Part 1 Jill 2C person on whose behalf transaction is conducted $52,500

#25 a Deposits $1,500
d Purchase of Negotiable Instrument $51,000
Total Cash In $52,500

Do you agree?

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#2268682 - 04/05/22 03:59 PM Re: CTR Help! Pepperjam_184515
BrianC Offline
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BrianC
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Posts: 6,240
Illinois
You also need Part I for Judy 2A person conducting a transaction on own behalf $500.
Last edited by BrianC; 04/05/22 04:00 PM.
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#2268683 - 04/05/22 04:05 PM Re: CTR Help! Pepperjam_184515
Susielou Offline
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Joined: Aug 2005
Posts: 337
Midwest
I still need that even though Judy only received benefit of $500?

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#2268684 - 04/05/22 04:18 PM Re: CTR Help! Pepperjam_184515
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,240
Illinois
Aggregation requires that we include transactions that are by or on behalf of the same person. Since Jill had more than $10,000 deposited on her behalf, we have to aggregate all parties to those transactions.

It's no different than multiple people depositing less than $10,000 each into a business account. We include all the people who made the deposits, not just the business that had more than $10,000 on its behalf.
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