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#820471 - 09/21/07 04:25 PM CTR Question
CrashDavis Offline
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Joined: Jun 2005
Posts: 283
Customer comes to bank and goes to teller and cashes a check for over $10,000 and turns around and deposits the cash into his daughter account. Check is on another bank. Do not understand why he just didn't deposit the check into daughter's account.
Also the same teller handles both transactions.

Question is do should we file a CTR and if we do how many one for cashing the check and one for the deposit.

Thanks for your help.

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#820514 - 09/21/07 04:56 PM Re: CTR Question CrashDavis
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Two large cash transactions, one a debit and the other a credit to cash, equals two CTRs.

The only reason I can think of for making it a "step transaction" was the possibility that he did not know how to endorse the check properly or he thinks the check might bounce and does not want you to have the right to take the money from his daughter's account.
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#820533 - 09/21/07 05:06 PM Re: CTR Question Elwood P. Dowd
M Cockrell Offline
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M Cockrell
Joined: Jan 2003
Posts: 1,049
Dallas, TX
possibly Dad has privacy concerns...

does not want daughter to know where the funds came from

or

does not want maker to know daughter has account?
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#820579 - 09/21/07 05:39 PM Re: CTR Question M Cockrell
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
If Dad didn't walk out the door and come back to make the deposit, a lot of banks would say the cash never left the bank, and they would not file a CTR. I'd agree with that view, as long as the cash didn't leave the teller's view between the two transactions.
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#822490 - 09/25/07 04:25 PM Re: CTR Question John Burnett
KeyJoe Offline
Junior Member
KeyJoe
Joined: Sep 2007
Posts: 33
Bucks County, PA
In reality, the customer should have deposited the check into his daughter's account or could have coded the transaction as cash even without cash coming across the counter.

As a former examiner, the bottom line is the door question. Did the customer enter or leave the premisies with cash in excess of $10,000 on his person? If the answer is no, please do not file a CTR. You are always free to consider filing a SAR.
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Joseph J. Englert, CRCM

Former examiner with the OTS with BSA/HMDA/CRA experience.


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