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#1631515 - 11/22/11 06:55 PM CTR Question
Grinchie Offline
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Grinchie
Joined: Apr 2001
Posts: 55
Virginia
We have two customers that have a joint account. They each present a cashier check issued for $15,000 to a teller to cash. (different transactions) Each received $15,000 in cash. Earlier in the day one of the individuals deposits $3,500 in cash into the joint account.

A CTR was automatically generated for the transaction of cash out. However, the Vertex system linked the two transactions together and the CTR was for a total of $30,000. When Vertex support was contacted they said the deposit earlier in the day linked the two individuals together because of the funds were deposited into a joint account and that the CTR was generated correctly.

I think two CTR should have been generated one for each of the transactions. Have I missed something?
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#1631592 - 11/22/11 08:17 PM Re: CTR Question Grinchie
What?? Offline
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What??
Joined: Feb 2007
Posts: 170
California
If I'm reading this correctly, two different individuals that hold a joint account with your bank cashed a $15,000.00 cashier's check each. Then one of them deposited some cash the same day. I would do the CTR for both on one CTR.

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#1632568 - 11/28/11 04:01 PM Re: CTR Question What??
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I would complete two CTRs, $15k each since the cashed check transactions are not linked in any way. The cash deposit is not an issue since it is under the reporting thresh hold.

I would not lose any sleep over this if you filed one CTR for the $30k out and identified both persons as persons on whose behalf the transactions were conducted. It is easily explained.
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#1632574 - 11/28/11 04:14 PM Re: CTR Question BrendaC
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I agree with Brenda. Although you may have tied those two cash-out transactions to the joint account by identifying the account for administrative purposes (Does the cashing individual have an account with you. If so, indicate the account number), they aren't related for CTR purposes unless you have, from some source that I can't imagine under the circumstances, information that the two individuals both benefited from each of the check-cashing transactions.
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