Skip to content
BOL Conferences
Learn More - Click Here!

Thread Options
#828653 - 10/04/07 01:40 PM CTR
LankerBady Offline
New Poster
Joined: Aug 2007
Posts: 17
Mississippi
Customer comes in and makes 4 deposits into checking about totaling $20,000.00. Then later the same day comes in and withdrawals $3,000.00 from the same account. How do you list this on the CTR? $20,000.00 in and 0 cash out because the $3,000.00 is less than the reporting threshold, or $20,000.00 cash in and $3,000.00 cash out?
_________________________
"It's not your blue blood, your pedigree or your college degree. It's what you do with your life that counts."

Return to Top
#828661 - 10/04/07 01:50 PM Re: CTR LankerBady
LoisLane Offline
Diamond Poster
LoisLane
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
The $3,000 cash out is not reportable because it doesn't exceed the $10,000 level....so $20,000 in and nothing out.
_________________________
And where is Superman when I need him?

Return to Top
#828663 - 10/04/07 01:53 PM Re: CTR LoisLane
LankerBady Offline
New Poster
Joined: Aug 2007
Posts: 17
Mississippi
Thanks So much!!!
_________________________
"It's not your blue blood, your pedigree or your college degree. It's what you do with your life that counts."

Return to Top
#829202 - 10/04/07 08:05 PM Re: CTR LankerBady
OVERWHELMED Offline
Member
Joined: Sep 2006
Posts: 92
the south
What about this one? Customer comes in two different times withdrawing 5000 and 8000...wife comes into different branch and withdraws 5000 from the same account. Husband and wife are not together at either branch. Just file CTR on husband for 13000 cash out or include the other 5000 and use both names?

Return to Top
#829299 - 10/04/07 09:56 PM Re: CTR OVERWHELMED
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Unless you have some info that indicates the wife and husband are getting the cash for the benefit of both, you should only consider the individual doing the transaction as the beneficiary. IOW, if I say "my wife are going on a shopping trip with this cash", then I think you would consider both as beneficiaries. Absent something like that, only consider the person present.

Specific to your scenario: file the CTR with the husband as the conductor and "conducted on own behalf" for $13,000. The wifes $5,000 is not a factor for the CTR.

However, is this typical for them to do this. This seems odd to me and maybe considered structuring. A total of $18,000 in cash was withdrawn by these two in one business day. You may want to investigate filing a SAR.
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top
#829583 - 10/05/07 02:12 PM Re: CTR David Dickinson
Milby Offline
Platinum Poster
Joined: Apr 2007
Posts: 953
Tejas
I'll concur with David...we had a husband/wife that would cash $5,000 - $8,000 checks each on the same day from the same account. They never made any assertion that the money was going for the benefit of each other, but we completed an investigation, filed a SAR, and then closed the accounts out.

Return to Top
#829590 - 10/05/07 02:18 PM Re: CTR Milby
OVERWHELMED Offline
Member
Joined: Sep 2006
Posts: 92
the south
I think the situation is this...they got a big settlement, backpay for disability or something...received a direct deposit for a large amount of money and are now going through it like crazy on some spending spree....they never really had money before the direct deposit came in from the US Treasurer.

Return to Top
#829705 - 10/05/07 03:20 PM Re: CTR OVERWHELMED
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,368
Galveston, TX
Make sure it was not from a ficticious/fraudulent tax return. You meant U.S. Treasury - right.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#833064 - 10/11/07 10:23 PM Re: CTR rlcarey
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
From 1995 Q&A on completing the then-new CTR,

Quote:
14. Question: Do all holders of the account, even if they do not come to the bank, need to be put on the revised CTR as "Person(s) on Whose Behalf Transactions(s) Is Conducted"?

Answer: For deposits, all those who are known to benefit from the transaction must be identified on the CTR. However, if a person makes a withdrawal from a joint account, only his name needs to be listed as the beneficiary of the transaction if: (1) he states that the withdrawal is on his own behalf or the financial institution knows that the person making the withdrawal is the only beneficiary, and (2) the financial institution has no reason to believe otherwise. [emphasis added]
Last edited by John Burnett; 10/11/07 10:25 PM.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  Lestie G