Skip to content
BOL Conferences
Thread Options
#618580 - 09/27/06 03:56 PM Cashed Checks and CTRs
presto Offline
New Poster
Joined: Sep 2005
Posts: 4
OH
If a person presents an on-us check in the amount of $12,000 and the bank issues a cashier's check payable to the person, is the transaction subject to a CTR.

Return to Top
BSA/AML/CIP/OFAC Forum
#618581 - 09/27/06 04:03 PM Re: Cashed Checks and CTRs
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
A CTR is only for when a body walks into or out of your bank with physical cash in excess of $10,000.00.
A check to check transaction would not warrant a CTR.

Return to Top
#618582 - 09/27/06 09:43 PM Re: Cashed Checks and CTRs
msitshane Offline
New Poster
Joined: Sep 2006
Posts: 6
I would offer a somewhat different view.

A CTR is when physical cash in excess of $10,000 is pushed across the teller window to the customer.

If the bank cashes the check and provides the customer with $12,000 in physical money, even if the customer pushes the cash right back (or if the bank's own records makes that transaction appear to have happened), I would file a CTR.

Return to Top
#618583 - 09/27/06 10:01 PM Re: Cashed Checks and CTRs
Sing A Little Offline
Power Poster
Sing A Little
Joined: Jul 2006
Posts: 3,889
CA
In this case a negotiable instrument was exchanged for a cashier's check, so no reportable cash transactions took place.

CTRs are used to report cash transactions (in or out) that are over $10,000 in a single day.
_________________________
He who sings scares away his woes. ~Cervantes

Return to Top
#618584 - 09/28/06 01:06 AM Re: Cashed Checks and CTRs
mck401 Offline
Diamond Poster
Joined: May 2006
Posts: 1,168
Texas
Sing is correct! In this case, no CTR or MIL is necessary as cash was not exchanged.
_________________________
Work less, play more.....why not????

Return to Top
#618585 - 09/28/06 12:38 PM Re: Cashed Checks and CTRs
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
Quote:

(or if the bank's own records makes that transaction appear to have happened)




I don't agree. I advise our tellers to look at what actually happened, not the way the transaction was run. For example, I see it sometimes when a CD is redeemed and a new one is opened. The daily report will show a cash out immediately followed by a cash in. If no currency was ever exchanged, regardless of what my report says, I don't complete a CTR just because the teller didn't run the transaction the way he/she should have. I then document that decision on my report.

Return to Top
#618586 - 09/28/06 12:50 PM Re: Cashed Checks and CTRs
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
I concur with Kelsey - reporting on appearances is a very dangerous practice. I would hate to be called into court during a government prosecution when they are accusing your customer of money laundering and you have to admit that they never "really" had possession of the currency.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#618587 - 09/28/06 12:52 PM Re: Cashed Checks and CTRs
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
A CTR is filed to report physical cash over $10,000.00 coming in 'off the streets' or going out of the bank.
i.e. a person walked out of the bank with the cash.
Period.
It is never filed for any internal transaction regardless of how the teller processed it.

Return to Top
#618588 - 09/28/06 02:47 PM Re: Cashed Checks and CTRs
JW Offline
Gold Star
Joined: Nov 2005
Posts: 269
Indiana
My general rule of thumb is "Did >$10,000 in cash come in or go out the front door?" If yes, file a CTR. If no, don't file.

Return to Top
#618589 - 09/28/06 03:11 PM Re: Cashed Checks and CTRs
Sing A Little Offline
Power Poster
Sing A Little
Joined: Jul 2006
Posts: 3,889
CA
The only other thing that I would add to the "false transactions" that can sometimes occur on a report is to document everything. We had several transactions like that occur on our reports when we had a batch of new tellers come in. We documented the research we did with the branches and kept copies of the actual transactions. Whenever our examiners had a question about these transactions during their review, we had our documentation ready, which made them very happy.
_________________________
He who sings scares away his woes. ~Cervantes

Return to Top

Moderator:  Andy_Z