Customer walks in and deposits $6000 on Monday, Jan 21. On Tuesday they bring in another 5000. For whatever reason our systems were coded that we would be closed that day, when we were open, so all of the postings from Monday have been posted on Tuesdays work.

So for the customer who over the course of actually two days-and would not trigger a CTR now shows over $10k in one day.

Should we aggregate the transactions for the CTR? - ( I realize we may have other structuring issues.)

Thanks.

Sounds like Monday was treated just like a Saturday which would require you to aggregate based on the next business day and not calendar day.

But if you were open on Monday and would have posted transactions on that day and prepared a balance sheet, etc for Monday if your system was coded correctly, I don't believe you should aggregate.

I don't know if the fact that the Federal Reserve wasn't open on Monday changes your days - even though you're open.

But it wasn't so .........

We have never aggregated Saturday to Monday-as transactions are posted live on Saturday. This day just happen to be a fluke. We have always posted these types of holidays regardless of whether the fed was open or not.

The instructions on the CTR say: For a bank, a business day is the day on which transactions are routinely posted to customers’ accounts, as normally communicated to depository customers.

This was a programming error, not a change in our business days.

Our customers would not have known the difference-nothing was "communicated" to them that we were not considering Monday as its own business day-just like any other day that we are open. The effective date of the the deposit was the 21st, the posting date the 22nd.

Biz,

I agree with your analysis: programming error. I would not report transactions aggregated only on that basis. However, in the next 12 days I would get someone on the Helpline or the EIC from my last BSA exam to bless my decision and write a memo to file about the conversation. This is not something I would want to discuss twice.

I did hear back from the helpline. They indicated not to aggregate and be sure to document it as a bank error. So Ken, you were right on! Thanks.