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#967304 - 06/02/08 01:37 AM CTR or no CTR
trainer82 Offline
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Customer A withdraws $10000 from her savings account in cash. Later the same business day, using a $100 bill, she deposits $60 into her checking account, receiving $40 cash back. Does the $40 cash back need to be aggregated with the $10000 from the savings withdrawal and a CTR filed?

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#967396 - 06/02/08 01:44 PM Re: CTR or no CTR trainer82
#Just Jay Offline
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IMO, no.
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#967525 - 06/02/08 04:21 PM Re: CTR or no CTR #Just Jay
WonderWoman Offline
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gone fishin'
*ditto* to Just Jay

But I would definitely put this person on my radar ...
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#967637 - 06/02/08 06:27 PM Re: CTR or no CTR WonderWoman
Deena Offline
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I'm curious as to why you wouldn't file a CTR. Didn't the customer technically walk out of the bank with more than $10,000 in cash when the two transactions are aggregated?
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#967695 - 06/02/08 07:53 PM Re: CTR or no CTR Deena
#Just Jay Offline
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#Just Jay
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Cheeseheadland
I would "technically" they walked out with $9640.

I do not view the $40 cash back out of the $100 as a withdrawl nor as a cach exchange. I see a $10k WD, and a $60 deposit.

I can see why some may consider the $40 cashback as a cash exchange out, but I do not.

Which ever way you choose to treat the $40, just be consistent with it going forward.
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#967711 - 06/02/08 08:05 PM Re: CTR or no CTR #Just Jay
I Wear Many Hats Offline
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the beautiful state of ME
Our system would aggregate this as:

$10,000 cash out + $40 Cash out = $10,040
minus your $60 cash in - = $9980 - total cash out -

not reportable - but kind of odd.....
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#967749 - 06/02/08 08:48 PM Re: CTR or no CTR I Wear Many Hats
CantBeShocked Offline
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I do not think that you are supposed to "net" out the transactions. You add deposits, add withdrawals - if either one is reportable, you report such amount on a CTR.
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#967882 - 06/03/08 01:05 AM Re: CTR or no CTR CantBeShocked
trainer82 Offline
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As it turned out, the teller who processed the second transaction ($40 cash back from a deposit) was prompted by the system to complete the CTR. Our central office said it wasn't necessary.
Thanks to all for responding.

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#968139 - 06/03/08 03:31 PM Re: CTR or no CTR trainer82
TXBSA Offline
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I would say it is necessary. You do not know for sure that the $100 was from the cash earlier in the day. She left the first time with $10000.00 and the second time with $40. I would say yes on the CTR.

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#968178 - 06/03/08 03:49 PM Re: CTR or no CTR TXBSA
Znatok Offline
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Definately CTR.

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#970355 - 06/05/08 09:15 PM Re: CTR or no CTR Znatok
John Burnett Offline
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I'll add my voice to the chorus that says you absolutely do not subtract the cash in from the cash outs to arrive at a net number. That's a strict no.

I could go either way on whether the $40 "change" is additional cash out. The odds of coming up with a similar scenario are slim, but I suggest deciding how your bank should have handled the day's transactions, and be consistent in the future.
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#970357 - 06/05/08 09:17 PM Re: CTR or no CTR John Burnett
John Burnett Offline
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For what it's worth, an additional thought: While thinking about odds, you should ask yourself whether the odds are greater of having this scenario questioned by an examiner if you file the CTR for $10,040 or don't file. And, if questioned, which option would be easier to defend. If you consider those questions honestly and practically, I bet you'd file.
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