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#695116 - 03/01/07 05:08 PM CTR 1b
KYBanker Offline
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Joined: Jan 2005
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What is the rule for selecting 1b when the CTR involves multiple transactions, some or all made via Night Deposit/ATM? How would one know if it was the same person or multiple persons? In this particular situation they are all coming in via the same night drop for a business account.

Also, as far as the audit trail goes, if the night drop is opened and then processed by a teller how do we prove it was a night drop deposit simply processed by the teller and not actually recieved by the teller? Is the Section B box good enough?
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#695126 - 03/01/07 05:18 PM Re: CTR 1b KYBanker
Sing A Little Offline
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Sing A Little
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Multiple persons is usually used when more than one person or entity is involved in the transactions (Ex. two people make deposits to an account, or a runner makes deposits to 2 different business accounts).

Are your night drop deposits processed in dual control? Do you log your night drop deposits? If you do, then that is your documentation. We've never had a problem with checking night drop in Section B, but we do log all of our night drop deposits for our records.
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#695138 - 03/01/07 05:28 PM Re: CTR 1b Sing A Little
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So if you do not have information indicating how many individuals were involved in multiple deposits via night drop to the same entity account, would it be wrong to select 1b?

Guidance indicated selecting 1b would trigger information on the back of the form; which seems to me would mean if you don't know you should not check box 1b...does that seem right?

If this is a recurring transaction (not able to be exempted yet) what are the implicaitons of Admin Ruling 99-2? Do we have an obligation to contact the business and get that info?

Sorry for the piecemeal question(s)!
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#695163 - 03/01/07 05:51 PM Re: CTR 1b KYBanker
Sing A Little Offline
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Multiple deposits to the same account via night drop would only be multiple transactions, not multiple persons.

Multiple persons would trigger the use of back of the form in order to accomidate all of the parties involved, but since the deposits are through the night drop you don't have to worry about that.
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