When cashing checks for non-customers, do you have a system to track aggregate noncustomer transactions for CTR purposes?

Our system captures CTR on non customer if the single transaction is 10K and greater, but not aggregate totals.

Lori

We used to capture for $3000 and over. We were often successful in matching multiple checks cashed by the same person. There is a limit based on your size how far you can drill down.

You may be able to automate if you want to take the extra steps to do so and your system permits. For example, in some teller systems (such as JHA Vertex) you can set the system to document the identify of each person cashing a check over a specific dollar limit (such as $1000 or $3000). Some banks love it; others not so much.

Thanks. We just converted to Metavante so I will need to check on functionality.

Just spoke with our processor and they can not aggregate non-csutomer cashing checks. Through reports we will be able to identify information regarding checks being cashed and then drill down, however, it will be after the fact and we will not have captured information that we are cashing the check on, ie. SSN.

Can you file a CTR without SSN# or other information on the person?

Missing information does not eliminate the CTR filing requirement.

A manual review system that aggregates based on payee names alone is going to be 1) time consuming (read expensive) and 2) ineffective in producing information that law enforcement can use.