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#611385 - 09/08/06 08:23 PM Threshold for Cash Agg report - 3 or 10?
Pinkie CRCM Offline
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Joined: Aug 2003
Posts: 399
KY
Playing the devil's advocate here...

If I have a cash agg report that will aggregate all accounts under an EIN, what benefit is it to me to have the report set at say $3000?

For example, if I have 20 different accounts under 20 different officers, that belong to 20 individual restaurants, let's say they are all 20 different Waffle House locations, and the deposits are made at 20 different branches because they are located near the 20 different restaurants. If my report will combine all the cash deposits made to the 20 different locations, into 20 different accounts, and gives me the grand total....why do I need to set the report lower than $10,000?

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#611386 - 09/08/06 08:29 PM Re: Threshold for Cash Agg report - 3 or 10?
BrendaC Offline
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BrendaC
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Posts: 6,029
Sweet Home AL
Examiners like to see the report thresh hold lower to serve as a tool for identifying possible structuring. Most of the regulators I have spoken with recently on this subject are recommending $6,000 - $7,500 as a thresh hold amount.
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#611387 - 09/08/06 08:53 PM Re: Threshold for Cash Agg report - 3 or 10?
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
We have ours set lower than $10,000 for that same reason, to identify structuring. We actually set ours at $3,000 because our monetary instrument sales appear on that report as well. On one report, we can ensure that all CTR's are filed and monetary instruments purchased in cash (3K-10K) are logged.

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#611388 - 09/11/06 01:54 PM Re: Threshold for Cash Agg report - 3 or 10?
BrendaC Offline
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BrendaC
Joined: Sep 2001
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Sweet Home AL
We are able to lower our threshhold on the account level. We lower our monetary instrument accounts to $3,000 and set our other accounts generally at $7,000.
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#611389 - 09/11/06 02:05 PM Re: Threshold for Cash Agg report - 3 or 10?
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
Quote:

We are able to lower our threshhold on the account level. We lower our monetary instrument accounts to $3,000 and set our other accounts generally at $7,000.




That's ideal. We're pretty small, so looking at everything over $3,000 isn't too cumbersome.

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#611390 - 09/12/06 04:43 PM Re: Threshold for Cash Agg report - 3 or 10?
Pinkie CRCM Offline
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Joined: Aug 2003
Posts: 399
KY
I'm still playing the devil's advocate

Quote:

for identifying possible structuring




Agreed. Here's another one. Let's pretend that a customer has 2 checking accounts and 1 savings account. My customer goes to Branch A and deposits $4000 into checking account #1. Then he goes to Branch B and deposits $5000 into the savings account. Lastly, he goes to Branch C and deposits $5000 into checking acct #2.

I would consider this structuring.

So, my cash aggregation report is set at $10,000, it WILL aggregate all these transactions (showing me the individual deposits).

So, if my report is looking for structuring and it's reporting it to me, why does it need to be set lower than $10,000? What else am I supposed to be looking for that would be under the $10,000?

Now, structuring transactions over the course of a couple of days is on a different report.

I know examiners want to see the report threshold lowered. Maybe there are other ways of structuring that I don't know about and if there is, would someone please enlighten me?

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#611391 - 09/12/06 05:14 PM Re: Threshold for Cash Agg report - 3 or 10?
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
Most customers who structure make deposits (or withdrawals) just under the $10,000 threshold (i.e. $9,500; $8,900; $9,200). If your report is set at $10,000 you may not see these.
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#611392 - 09/12/06 05:15 PM Re: Threshold for Cash Agg report - 3 or 10?
rdelgado Offline
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Joined: Dec 2005
Posts: 116
Quote:


Now, structuring transactions over the course of a couple of days is on a different report.

I know examiners want to see the report threshold lowered. Maybe there are other ways of structuring that I don't know about and if there is, would someone please enlighten me?




I'm no expert, but I think you just answered your own question. Examiners don't say that the report you use to identify CTR activity HAS to be the same report you use to identify suspicious activity. If you have another report that has adequate rules set to catch structuring trends or patterns/unusual activity, then by all means, leave the other report set to only capture CTR transactions.

But I will also throw this in regarding lowering the threshold. It has become something of common knowledge that banks have "thresholds" to red flag activity. Many people have been caught (at least at my bank) trying to stay below THOSE thresholds...which they often guess based on public information that talks about what a "good" threshold would be.

A common one is $5000, so I end up seeing cash activity in personal accounts that remain at $4000 and $4500. If i did not have a report with a threshold low enough to see these low dollar transactions that make no sense**, then I've failed to properly do my job.

**This is another example of why the threshold would be requested to be lower, activity outside of the norm for a specific account, or type of account, would likely go undetected, or detected in an untimely manner if thresholds are set too high. However, that's assuming that your other reports don't catch this type of activity.
Last edited by rdelgado; 09/12/06 05:19 PM.
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#611393 - 09/12/06 05:38 PM Re: Threshold for Cash Agg report - 3 or 10?
A_G Online
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Posts: 18,989
Quote:

We are able to lower our threshhold on the account level. We lower our monetary instrument accounts to $3,000 and set our other accounts generally at $7,000.




Can I ask what service provider you are using...this would be ideal here!!!
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#611394 - 09/12/06 05:54 PM Re: Threshold for Cash Agg report - 3 or 10?
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
We have our report set at 3K. Our regulator (OCC) said that they are seeing terrorist activity at lower amounts....
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#611395 - 09/12/06 06:03 PM Re: Threshold for Cash Agg report - 3 or 10?
Pinkie CRCM Offline
Gold Star
Joined: Aug 2003
Posts: 399
KY
Thank you posters! I was having difficulty trying to explain why there IS a need to have the reports set lower and couldn't get everyone off the idea of structuring. They kept saying "But you WILL catch the activity and it will be reported", and "you do not need to look at all the other activity, because it is not related to structuring."

...sigh...Is it Friday yet?? Thanks again everyone!

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#611396 - 09/12/06 07:24 PM Re: Threshold for Cash Agg report - 3 or 10?
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
A couple of unsolicited comments:

First, you can make the sieve as fine as you want. If it's too fine, the bank's reports will either drive you to drink because of their volume, or become so utterly useless as to cause you to ignore them. This is a balancing act of sorts, so don't get too enthusiastic about setting parameters lower.

Second, if you look carefully at the definition of "structuring" in the regulation, you'll see that it can involve transactions at different banks and on different dates. That argues in favor of having some form of report that identifies large, but not reportable, currency transactions by your customers.
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