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#365136 - 05/27/05 09:15 PM Opinion/Feedback requested - CTR completion
AnnRoy Offline
Platinum Poster
Joined: Jun 2002
Posts: 771
Here's the scenario: Bank customer has a split deposit for $40,000 (not on-us check)and made deposits to checking/saving accounts and made loan pymts; rec'd $12,000 cash back. How would you complete Part III? Show total cash out as $12,000 of course but would you check - negotiable instrument cashed and/or deposits and list the account numbers affected (DDAs and loan accounts)?

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#365137 - 05/27/05 09:48 PM Re: Opinion/Feedback requested - CTR completion
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
The account numbers were not affected by the cash. Leave this section blank and indicate "negotiable instrument cashed."

You cashed a portion of a check. That's what your report should reflect.
Dolly Nugent
Opinions expressed are my own.

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#365138 - 06/06/05 05:31 PM Re: Opinion/Feedback requested - CTR completion

New situation, looking for opinion/feedback:

Client brings in $15K on-us check, takes $3K in cash and purchases $12K cashier's check payable to a local business. Cash never physically changed hands in an amount over $10K. My thought is, he wanted to cash his check and purchase a cashier's check, otherwise he would have deposited to his account and paid for the CC with a check. I am thinking a CTR should be filed, and possibly a SAR if I talk to the teller and we decide this was done as an attempt to avoid filing.

I can argue both sides of the issue in my head, can anyone give me advice on what your bank has done / what would be the compliant way to handle the situation please.

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#365139 - 06/06/05 05:35 PM Re: Opinion/Feedback requested - CTR completion
Sound Tactic Offline
Power Poster
Sound Tactic
Joined: Feb 2005
Posts: 5,349
From what I know a CTR cannot be filed. But dont take my word for it, I do not file them or review them for our bank. A SAR, probably.
If your tagline references disclaimers regarding the nature of political posts, then you should just hit notify.

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#365140 - 06/06/05 05:43 PM Re: Opinion/Feedback requested - CTR completion
Big Dog Offline
Power Poster
Big Dog
Joined: Mar 2005
Posts: 2,659
CTR is not required. The customer walked in with a negotiable instrument and he walked out with one. The $10,000+ limit was not hit.

If you suspect this is an illegal transaction in some way, then it would be reportable on a SAR. On the surface, the person wanted good funds without the hastle of waiting for a personal check to clear. Took some cash and wanted the balance in a cashiers check. Seems OK to me.

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#365141 - 06/08/05 03:14 PM Re: Opinion/Feedback requested - CTR completion
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,544
Cape Cod
big-dog is offering good advice. This is most definitely NOT a CTR situation.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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