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#810081 - 09/06/07 02:37 PM CTR filing/ exemptions in case of bank mergers
Curious Offline
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Joined: May 2004
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2 banks A and B merged in a single charter but retained their names - Bank A and Bank B. An exempt customer of Bank A (not exempt at Bank B) deposits $3,000 at Bank B and $8,000 at Bank A.
While Bank A will not file CTR (exempt customer), is Bank B required to file CTR, if it has knowledge of the 2 transactions?
[I do not need help regarding SAR, but will appreciate guidance and reference regarding CTR].
Thanks

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#810109 - 09/06/07 02:52 PM Re: CTR filing/ exemptions in case of bank mergers Curious
David Dickinson Offline
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Central City, NE
Bank A and Bank B no longer exist. They are one charter. THE bank (the merger of "A" and "B" - I'll call it "Bank C") had multiple cash deposits totaling $11,000. Bank C needs to have a system to monitor multiple cash activities between all locations. IOW, you need to have knowledge of these types of activities and file CTR accordingly.

Whether Bank C needs to file a CTR depends on if this customer is exempt or not. Did the exemption (originally from Bank A) continue with the new merger? If so, no CTR should be filed. If not, file a CTR.
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#810154 - 09/06/07 03:17 PM Re: CTR filing/ exemptions in case of bank mergers David Dickinson
Curious Offline
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Joined: May 2004
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David, the only reason for the complication is that there is no merged bank. The banks continue to operate as Bank A and Bank B. Further, the systems enable identification of transactions across banks. Due to this Bank B is aware of the transaction at Bank A.
In light of the above, I am still looking for answer.

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#810229 - 09/06/07 04:10 PM Re: CTR filing/ exemptions in case of bank mergers Curious
I Wear Many Hats Offline
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I Wear Many Hats
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Posts: 591
the beautiful state of ME
I guess, I am confused by your terminology - if you have one charter, then there is one bank - despite the name retention - which is often done for branding purposes. You would have two banks, if the "one" entity is a holding company and the banks are two entities under the holding company umbrella. If it is the latter, then you have two banks, so no CTR. If it is the former, which it sounds like it is, if you have the same system in place, then your exemptions should flow between the two institutions, and your CTR reporting should do so as well. We have a couple of banks in our area that are, in merger situations, retaining their names even though systems, etc., are mergered. There are becoming "XYZ Savings" a division of "ABC Savings". If the name is for branding only - then you are a merged insitution and need to treat all accounts as belonging to that one chartered entity.
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#810574 - 09/06/07 07:27 PM Re: CTR filing/ exemptions in case of bank mergers I Wear Many Hats
Retread Offline
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Retread
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This does not totally fit your situation, but it may give you a place to start.

http://www.fincen.gov/fincenruling2001-1.pdf
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#810821 - 09/06/07 10:27 PM Re: CTR filing/ exemptions in case of bank mergers I Wear Many Hats
David Dickinson Offline
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David Dickinson
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Central City, NE
Originally Posted By: Kate & Tim's Mom
I guess, I am confused by your terminology - if you have one charter, then there is one bank

I'm confused too. Did the bank's merge (one bank) as you said or not? Please provide clarification and we'll see if we can help.
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http://www.bankerscompliance.com

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