We are having a difference of opinion on filing a CTR. We had a customer come in with $9,900.00 in cash to pay on a loan. He then took out another loan, received it in cash, then took $1200.00 of this money and paid it towards the one he just paid the $9,900.00 on. I say that since he only came into the bank with the $9,900.00 we are not required to file a CTR, someone else thinks that since and additional $1200.00 exchanged hands we would need to file one. I had an examiner tell me that you only file a CTR when the customer actually walks in or leaves with more than $10,000.00 in their hands. Could we get some help on this.

I agree with you- no CTR. I'm assuming that the $1,200 payment was the result of a bank loan.

Was the $1200 a suspense entry masquerading as cash, or did the $1200 in currency actually cross the counter and then cross back? If the customer took possession of the currency and handed it back to the bank, I'd file.

Either way- this is a really strange set of transactions. Making a large cash payment against a loan, only to turn around and get another loan (and more cash) is not typical.

$9900 through the door--no CTR. Due diligence review--definitely.

I've always been told that if more than $10000 cash changes hands across the teller line, a CTR is required.
You can always call the DCC hotline at 1-800-800-2877 to get an answer. Make sure you write down who you talk to and what they say, because they generally don't send you anything in writing.
I would definitely look into this though...$9900 cash looks a lot like structuring to me.

I agree. "Through the door" usually is a good test, but the counter is where the exchange actually takes place, so that's the turnstile that the CTR cares about.

The scenario is thankfully rare. That's a good reason not to have run across the "right" way to count the cash in. If you can't get a response from DCC, go ahead and file the CTR and count the $1200, and move on. It's not a high-risk error if the CTR ultimately should not have been filed.

But if you do get a response from DCC, share it with us, please.