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#604120 - 08/23/06 09:33 PM CTRs & Exemptions - Rookie BSA'er
HubbaBubba Offline
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Joined: Sep 2002
Posts: 311
A few questions:
1. How many reportable transactions would a business need to have in a 12 month period in order to be exempted?

2. How many names do you list on a CTR for a reportable transaction? Say it is a joint account with 4 names?

3. Does it makes sense to have to report US currency exchanges for US currency? I can understand US currency exchanged for foreign currency.

Thanks for any input!
Last edited by Ken_Pegasus; 08/24/06 01:25 PM.
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#604121 - 08/23/06 09:54 PM Re: Rookie BSA'er
mck401 Offline
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Joined: May 2006
Posts: 1,168
Texas
Those are great questions. I'll do my best to answer them.
1. 8 transactions within 12 month period
2.You would list all names that benefited from the transaction. If there are 4 on the joint account; all 4 would be listed for a deposit. If 1 person cashed a check, then only that person's information would be captured.
3.Yes. Currency exchanges, even US money for US money is reported. Smaller bills for larger and vice versa. This could be one method to 'launder' money.
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#604122 - 08/23/06 09:57 PM Re: Rookie BSA'er
Dip Offline
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Posts: 6,298
San Diego, CA
good answer mck, fellow BSA newbie :-)
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#604123 - 08/24/06 12:58 PM Re: Rookie BSA'er
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
I stuggle with #2 sometimes. We don't always have the driver's license and occupation on file for our account holders, so if the wife makes the deposit and the husband is not present but is a joint account holder, how do we collect his information? I'm not questioning whether or not we're supposed to because I know that we are. I just wonder how other banks are gathering all of the information they need for beneficiaries that aren't present at the time of deposit.
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#604124 - 08/24/06 01:10 PM Re: Rookie BSA'er
arye Offline
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arye
Joined: Oct 2004
Posts: 464
Ohio
Welcome to BSA Kelsey!

For benefactors not present during the transaction (wife makes deposit into joint account and husband is not present, as in your example), you do not have to report identification information for the person not present. Check out the instructions for completing FinCEN form 104 for guidance.

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#604125 - 08/24/06 01:40 PM Re: Rookie BSA'er
Compliance2U Offline
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Joined: Apr 2006
Posts: 110
Midwest
Remember under #3 it is like currency exchanges. For example all out's are aggregated and all in's are aggregated. You don't add the total of in's and out's to come up with a total exchanged.

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#604126 - 08/24/06 01:50 PM Re: Rookie BSA'er
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Quote:

3.Yes. Currency exchanges, even US money for US money is reported. Smaller bills for larger and vice versa. This could be one method to 'launder' money.




An example: Smaller bills coming in for larger bills would be indicative of street level drug sales.

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#604127 - 08/24/06 02:14 PM Re: Rookie BSA'er
Kelsey D Offline
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Posts: 516
Ohio
Quote:

you do not have to report identification information for the person not present.




Are you saying that in my example I would list the husband on page 2, Part I, Section A, but leave the identification information blank? Where can I find this quidance?
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#604128 - 08/24/06 02:32 PM Re: Rookie BSA'er
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,793
Cape Cod
It's in the instructions for the CTR, listed under Item 14, bottom right corner, page 3 of the form.

Unfortunately, to save copying or printing costs, most banks don't include pages 3 and 4 of the form when they reproduce it for use. Those pages have the instructions for the use of the form.
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#604129 - 08/24/06 02:44 PM Re: Rookie BSA'er
arye Offline
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arye
Joined: Oct 2004
Posts: 464
Ohio
Quote:

Quote:

you do not have to report identification information for the person not present.




Are you saying that in my example I would list the husband on page 2, Part I, Section A, but leave the identification information blank? Where can I find this quidance?




Yes...that is right.

Mr. Burnett posted where to find the information on the instructions to complete the CTR. To find the instructions themselves, you can go to the IRS website, search for "Form 104" and print off/save a copy the entire Form 104, which will include the instructions.

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#604130 - 08/24/06 02:47 PM Re: Rookie BSA'er
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
Wow! I've read those instructions several times but have never caught that. Thanks for your help!

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#604131 - 08/24/06 02:47 PM Re: Rookie BSA'er
arye Offline
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arye
Joined: Oct 2004
Posts: 464
Ohio
Anytime

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#604132 - 08/24/06 05:20 PM Re: CTRs & Exemptions - Rookie BSA'er
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Don't forget--you only need one transaction to exempt a Phase I entity. The magic "8" is for Phase II customers (i.e., eligible non-listed entities and payroll customers).
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