I can't believe I've never ran into this situation....

Customer has a checking and savings in her name/ss#. There is also a savings account in the daughters name/ss# with the mother as custodian because it is a minor account.

Customer was in on the 1st and w/d $4K from her savings in cash.
Customer came back in on the 2nd and deposited $4000.00 in the savings (presumably the same 4K she withdrew the day before), $2K into her checking and then $7K into the daughters/minor account. Cumulatively the mother has deposited $13K in cash into accounts in one day. A CTR was not generated by the system obviously because the minor account has a different CIF and SS# due to titling. What type of reporting would any of you do?

Thanks for your input!

Most definitely, because you have knowledge that the same individual conducted all of the transactions, you must file a CTR for the cash-in transactions made on the 2nd. File it for a total of $13,000, with section A entries for Mom and for Daughter. Put Mom on the front of the form and daughter on the back. Check "conducted on own behalf" in Part B. List in Part II all three account numbers.

The withdrawal on the 1st day doesn't get reported.

You ask about a SAR. You have to decide whether the customer's transactions are suspicious. I suggest you contact the customer to find out about the transactions, unless you know the source of that cash. $13,000 cash deposits aren't generally made to personal accounts, are they? If the transactions seem suspect, then the bank may decide to file.

Thanks John!