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#910095 - 02/25/08 09:43 PM Is it considered structuring when......
MK Offline
Member
Joined: Apr 2006
Posts: 62
Florida
A customer asks about the CTR reporting threshold, is given the "Facts You Should Know Brochure" then deposits less than $10,000.01 into an account? In this particular situation, the bank employee who accepted the deposit did not see if the customer had any other cash besides what was deposited.

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#910116 - 02/25/08 09:57 PM Re: Is it considered structuring when...... MK
80's Lady Offline
Gold Star
Joined: Apr 2007
Posts: 295
Since the bank employee did not see the customer alter or change a deposit ticket or reduce the amount of cash they were holding, I would not automatically consider this structuring. It sounds like the customer made the inquiry, was handed the brochure and then handed the cash right over.

Of course I'm sure you plan on monitoring the deposits into the account for the forseeable future! A few more deposits such as this in a short time-frame that deviate from the customers normal pattern would be cause for concern.
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I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!

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#910152 - 02/25/08 10:39 PM Re: Is it considered structuring when...... 80's Lady
Little Miss BSA Offline
Diamond Poster
Little Miss BSA
Joined: May 2007
Posts: 1,185
Miami
I would make some kind of note of the above mentioned incident so that you remember what happened later on when you possibly stat seeing cash deposits/withdrawls below the reporting threshold for the same customer.
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#912270 - 02/28/08 06:00 PM Re: Is it considered structuring when...... Little Miss BSA
arye Offline
Gold Star
arye
Joined: Oct 2004
Posts: 464
Ohio
If the customer held back money (teller saw them keep funds instead of depositing all) or changed the deposit slit, automatic SAR.

If no money was seen and this was viewed as a customer inquiry, we would look at the customer's transactions and see if they pushed the threshold for reporting outside of their normal pattern of activity (similar to other posters). Of course this is all dependent on the tolerance of your BSA Officer, or your regulator!! (whether or not is should be is a whole other thread!)

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