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#1656064 - 01/25/12 09:36 PM 1 Runner, 3 businesses
Jasmine Offline
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Jasmine
Joined: Jul 2002
Posts: 149
Massachusetts
We have 1 runner who comes to the bank daily with deposits for 3 separate businesses. They are all family members, but the runner is not on any of the accounts, and the 3 business accounts have different names, owners and signers. Question: If the runner walks in with over 10k in cash, but splits it between the 3 businesses, so that no 1 business gets more than 10k, do we need a CTR?

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#1656093 - 01/25/12 10:15 PM Re: 1 Runner, 3 businesses Jasmine
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,694
Illinois
A CTR is required if more then $10k is deposited "by or on behalf of a single individual."

In your example, more than $10k is deposited by a single individual so you would complete 3 section A's for the three businesses and the runner's information in Section B.
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#1656163 - 01/26/12 10:44 AM Re: 1 Runner, 3 businesses Jasmine
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Aggregation is required for the reason given, but in the future your attention needs to be focused on whether the "businesses" are 3 different entities, not who owns them or who signs on them. That is, determine if they are corporations, LLC's, sole proprietorships, etc.
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#1656194 - 01/26/12 01:55 PM Re: 1 Runner, 3 businesses Elwood P. Dowd
Jasmine Offline
100 Club
Jasmine
Joined: Jul 2002
Posts: 149
Massachusetts
Thank you both for your responses. They are 3 corporations, by the way. I agree that a CTR must be filed, but our auditor said that we did not because the accounts were not mingled. I just keep repeating that 1 person walked into the bank with more than 10k in cash.

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#1656209 - 01/26/12 02:15 PM Re: 1 Runner, 3 businesses Jasmine
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Your auditor's remedial reading assignment:

(b) Multiple transactions. In the case of financial institutions other than casinos, for purposes of the transactions in currency reporting requirements in this chapter, multiple currency transactions shall be treated as a single transaction if the financial institution has knowledge that they are by or on behalf of any person and result in either cash in or cash out totaling more than $10,000 during any one business day (or in the case of the U.S. Postal Service, any one day). Deposits made at night or over a weekend or holiday shall be treated as if received on the next business day following the deposit.

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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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