I recently found this while searching for a tool to help our supervisors review CTRs before filing.

http://finsolinc.com/CURRENCY%20TRANSACT...20CHECKLIST.pdf

It's on the site of "Financial Solutions", and I assume since it is posted on the web and readily downloadable, it can be used by anybody. Somebody put a lot of time and effort into this, and I think they did a great job.

I agree that someone put alot of time into this but I do not agree with all of the instructions. For example, it says that Box d should never be completed when Section B contains information, but I disagree. When there are multiple transactions and we know at least 1 of the conductors but not every conductor, I believe it is correct to provide the information on the conductor(s) and also check Box d. Am I wrong?

"Box d should never be completed when Section B contains information"

Mine says Box d in Section B is never completed when Section B is "complete". That is correct. If you have all parties identified in Section B, there is no need to check box d because that box implies that there is missing information.

Devsfan, I agree with you. I believe you can mark both. I believe that if the teller did not collect the information on the conductor because it was multiple transactions that triggered the CTR requirement, then checking box D would be the reason for the section being blank or having information on only one of the conductors. It is always best to include as much information as possible on the CTR. Checking boxes A-E in Section B, would be the reason for a blank or incomplete section, so that it would not appear as an exception or that the information in that section was overlooked.

I am sure that Section is open to interpretation, but that is just my opinion.

But you may be missing some or all information on one or more of the transactors. If you only have a name and address of the transactor, then you should at least put the information that you have and checking box d will indicate why you did not provide all necessary information on the one or more transactors.

"Mine says Box d in Section B is never completed when Section B is "complete"."

I think we may be talking about different things. To me, if Section B is complete, that means all information is there. If all of the information is there, there is no need to check box d which implies there is missing information. Of course, if there is missing information, you check box d, but the check list says when Section B is "complete".

OK, Company A has a cash deposit for $900. Do you ID the person making the deposit? We don't. Later in the day, a different person comes into the bank and deposits $9,500. You ID the person based on your procedures or the system may prompt you because the company now has over $10,000 cash deposited.

You have all the information for 1 transactor, but not the other. You either contact Company A and request all required information on the first transactor, or mark box d, since you do not have all information on all transactors.

You are exactly right. If you did not identify the person making the first deposit at the time the deposit was made and could not obtain identification later, Section B would not be "complete", therefore, you would use box d. If you obtained all of the information on all of the conductors, Section B would be "complete" and you would not check box d.

Right, you would have one complete section B and one not complete, therefore you would complete section B on page 1 and check box d.

Also, remember in this situation, you would be checking box 1b for multiple persons (which is a flag for a second page), but by marking section B box d, you are letting them know that you did not obtain all the information and may not have a second page.


The problem with CTR's is that there are so many different variables that it is difficult to write on good procedure for the average branch person to follow. They just don't see enough of the variations to know what to do or determine which scenario is correct.

Once, I saw a bank attorney give the bank's new associate counsel a stack of Regulation Z disclosures and ask him to go through them looking for errors. As expected, the newer attorney came back in a couple hours and acknowledged, "I don't know what I'm doing." He was then instructed to make a review checklist like this one.

Like this review checklist, it would not serve as a procedure for form completion; i.e. it would not address every possible nuance. However, also like this one, it provided an organzied methodology for reviewing documents for proper completion and, after the user had relied on it for some time, it would eventually be unnecessary. This is an excellent tool.