Our processor released an enhancement that allows us to capture the amount of cash back from POS transactions conducted using a debit card. The enhancement was done to allow that cash amount to be aggregated with other cash out for the same customer for CTR reporting purposes. I would never have thought to aggregate these two types of cash out transactions for CTR reporting. Can anyone tell me if it is required???

The more that some bankers do to pull every possible cash transaction under aggregation, the more the "bar" gets raised for financial institutions generally. When your customer obtains cash at an ATM or via POS cash-back, it's considered just like making a cash withdrawal. To the extent that your system is able to aggregate those cash amounts with other cash withdrawals, you are expected to do so.

MAG, who is your system processor?

We had that comment during our last BSA exam and determined that our system was not capable of determining the cash back on POS at that time. Just curious to see if it may be something that we will have to deal with in the future.

Thanks!