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#1197707 - 06/08/09 11:47 PM Reflecting loan payment on CTR (conflicting advice
daysailor Offline
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Joined: Feb 2007
Posts: 51
I would like some final guidance on how to reflect a cash loan payment or payoff on a CTR. I've attended 3 BOL Top Gun conferences and in the first one in Las Vegas, we were advised to mark box 31 for negotiable instrument purchased when a cash loan payment was made. In 2008 at the San Francisco conference the material for the Training for CTR Completion: The Unanswered Questions session stated that item 36 (other) should be checked and loan payment specified. It also stated that item 35 should be checked and the loan account number be provided. This year at the Las Vegas conference, the materials for the Common Violations session stated "Box 31 is to be checked if a loan payment is made (it is not a deposit)." I believe that marking box 35 and 36 and specifiying the loan account number and loan payoff is the correct answer.

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#1197720 - 06/09/09 01:58 AM Re: Reflecting loan payment on CTR (conflicting advice daysailor
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Betsy is FinCEN's CTR maven and represents the "final guidance" in my book. From one of her recent slide shows:

From GUIDANCE ON THE NEW CURRENCY TRANSACTION REPORT (CTR), 1995 (#27):

Question: How should such transactions as loan and credit card payments be reported?

Answer: Transactions such as loan and credit card payments should be indicated and described in Item 36 (Other) with account numbers affected recorded in Item 35

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#1198049 - 06/09/09 05:32 PM Re: Reflecting loan payment on CTR (conflicting advice Elwood P. Dowd
daysailor Offline
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Joined: Feb 2007
Posts: 51
Thanks Ken.

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#1198186 - 06/09/09 07:46 PM Re: Reflecting loan payment on CTR (conflicting advice Elwood P. Dowd
Islandgirl Offline
100 Club
Joined: Nov 2005
Posts: 182
Louisiana
I wonder if you have been doing it incorrectly in the past by checking the box for "Deposit/Withdrawal" if it makes any differnce?

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#1198188 - 06/09/09 07:46 PM Re: Reflecting loan payment on CTR (conflicting advice Islandgirl
Islandgirl Offline
100 Club
Joined: Nov 2005
Posts: 182
Louisiana
I guess I need to work on my spelling!

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