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...)