Non customer comes in with a check drawn on one of our customers IOTA accounts. Purchases a cashier check and walks out with $25,000. The teller did not cash the IOTA check. She ran it in her work with the credit copy of the cashier check and a cash out of $25,000 as she was instructed to do by her Manager. With the transaction processed in this manner, I am not sure how the CTR should read.The CTR produced by our system doesn't appear correct to me. I would appreciate some guidance on how to proceed with this CTR. PLEASE?? Would like to avoid sending in an incorrect CTR!!

What does your system say?

I'm confused...what was the amount of the check drawn on the IOTA account?

The check on the IOTA account was $100,552.79, cashier check was $75,552.79 and cash out was $25,000...CTR was produced for $25,000 with Negotiable Instrument purchased marked in Part 2 of the CTR.

Think about the CTR as a tracer document; if you want to use the CTR to find this transaction a year from now, where would you look?

The transaction is a potpurri. Check box 32, negotiable instrument cashed, and include the relevant account number on the CTR. That's the portion of the transaction that generates the CTR.

However, I would also check box 31, Negotiable instrument purchased and include the GL account number as well. Subsequent commenters may critique this part of the suggestion and you may choose to run it past FinCEN. However, the advice is in support of my stated goal of being able to use the CTR to find the transaction months later and simply describing the cash portion will not allow me to do that without additional steps..

I am reluctant to check Box 32 only because they did not cash the IOTA check.......I think that is the root to my confusion.... as of now, I have checked box 35 and have the IOTA account number listed, box 31 is checked and 34.....

Thank you soooo much for your input!!!

I just added box 32 with the GL number....I feel like that will tell the complete story of these transactions.

Yes, they did cash the check - just only partially.

Consider the fact that when a check is deposited and cash is taken back from the deposit ticket, you are instructed to treat the transaction as the cashing of a negotiable instrument. That's directly parallel to the transaction you've described.