I just received a CTR for review that has me puzzled.
1- A customer comes in and purchases several cashier's checks with cash in excess of $10,000. When asked to provide information to complete the CTR she states she is doing this on behalf of a Family Trust. The cashier's checks she purchased show our customer(the purchaser) as the remitter. The trust is not mentioned on the check.
Since she has advised us that the money is from the Trust we will show the Trust in section A. (We are also listing her in "A" since she is listed as the remitter on the check). (and section B as the purchaser)
1- For the Trust would you just put "family trust" as the occupation or business?

2- The teller completed section A for every payee on every check. We normally do not list the payee of each check.
Should the payees be listed?

The payees should not be listed. You would perform a CTR on them if they actually came into the bank and cashed the check and the transaction was in excess of $10,000.

I would not list the trust either.
Isn't that just hearsay?
She may have a trust account with you, but the money still came from 'off the streets' - if I am reading your scenario correctly.

I agree. If the trust is not on the account or the payee on the checks, how do you know the trust is really involved or even exists? I would list the individual customer who conducted the transaction.

We have always been told to ask on whose behalf the transaction was being done. When she volunteered the information we thought it would need to be listed. Now that you have mentioned this I think I will talk to our regulator and get their opinion.
thanks for all the responses.

hbComp, when you get a response from your regulators will you share that info with us? I agree that if the individual states the transaction is being conducted on behalf of someone other than the individual conducting the transaction that you list that person in section A- in this case it would be the trust. I am curious as to what you will find out. Thanks.