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#2184196 - 07/05/18 05:54 PM Cashing not on us check and account number
Always In Training Offline
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Where the Green Grass Grows
I've searched, but my search game is not strong today.

We only cash not on us checks to customers, but we don't require that the customer deposits the check, then withdraws cash from the account.

I have a CTR that we filed showing the cash taken out of the bank and negotiable instruments cashed. The account numbers on the check would not be our account numbers. My regulator requested that I amend the CTR to include my customer's account number. I was fairly certain that if it did not affect the customer's account, I didn't need an account number. But, like I said, my search game is not so strong today. Can someone point me in the right direction? I'm contacting FinCEN next.

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#2184201 - 07/05/18 06:15 PM Re: Cashing not on us check and account number Always In Training
bcompliance Offline
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You are correct, you may want to check the CTR Filing Instructions or the FAQs. Not sure where that citation is either.
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#2184203 - 07/05/18 06:20 PM Re: Cashing not on us check and account number Always In Training
Daisy Doodle Offline
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Our teller software requires an account 'reference' number (our account number) for check cashing. We require checks over $2,000.00 to go through an account prior to cashing. But we do not report the other account number, just ours. Yikes. Should we be?

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#2184204 - 07/05/18 06:25 PM Re: Cashing not on us check and account number Always In Training
Always In Training Offline
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Where the Green Grass Grows
We read the embedded instruction on the CTR together it isn't clear, and the FAQs don't seem to address this. I honestly think both are acceptable, just expected to be consistent about it per your own procedures.

I emailed FinCEN, waiting on that answer I'll print that out with the CTR if they back me up and I'll amend if they back up regulator.

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#2184205 - 07/05/18 06:28 PM Re: Cashing not on us check and account number Always In Training
Always In Training Offline
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Joined: Jul 2006
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Where the Green Grass Grows
My cash tickets have an account number for cash tracking to the customer level, but examiner's stance is our customer HAS an account here, the CTR should have our customer's account number on it. My stance is, the negotiated item didn't affect the customer's account, if you pulled a statement, the item would not be reflected on the account activity and I don't require the item to be deposited. I know some places do, but my system will track the cash without the two transactions.
Last edited by Always In Training; 07/05/18 06:29 PM.
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#2184211 - 07/05/18 07:13 PM Re: Cashing not on us check and account number Always In Training
bcompliance Offline
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Joined: Sep 2014
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FinCEN may be your best bet, but here is an old thread i found:

https://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1813088
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#2184220 - 07/05/18 07:36 PM Re: Cashing not on us check and account number Always In Training
HappyGilmore Offline
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Pulling people out of the ditc...
Originally Posted By Always In Training
I've searched, but my search game is not strong today.

We only cash not on us checks to customers, but we don't require that the customer deposits the check, then withdraws cash from the account.

I have a CTR that we filed showing the cash taken out of the bank and negotiable instruments cashed. The account numbers on the check would not be our account numbers. My regulator requested that I amend the CTR to include my customer's account number. I was fairly certain that if it did not affect the customer's account, I didn't need an account number. But, like I said, my search game is not so strong today. Can someone point me in the right direction? I'm contacting FinCEN next.


so how do you know where to charge it back if it is returned if your customer account is not noted on the check? our process, whether good or not, requires the customer to deposit to their account and then write a check against the account. then we have no issues such as "who gets listed in the CTR" (not saying that we don't open up to other issues, but hey...)
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#2184225 - 07/05/18 08:20 PM Re: Cashing not on us check and account number Always In Training
Always In Training Offline
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Joined: Jul 2006
Posts: 1,115
Where the Green Grass Grows
But I know who gets listed on the CTR. And even before account numbers were listed on cash tickets, I could chase who cashed the check and charge it back through electronic proof files and images.

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