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#1519464 - 03/09/11 06:09 PM CTR - two people involved - report both?
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
I don't know why I'm second guessing this - but here's the scenario. I already know it's a SAR - so let's just look at the CTR.


Noncustomer comes in with customer. Noncustomer has a check for $14,000. They deposit it into customer's account.

Customer writes check to noncustomer for $10,000 - non customer cashes check.

Customer writes herself a check for $4,000 - and cashes the check.

This is all done at the same time at the same teller window.

Do they both go on the CTR - or because technically neither one benefitted over $10K (based on the way they conducted the transactions - though I feel otherwise, hence the SAR) - no CTR is required?
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#1519481 - 03/09/11 06:33 PM Re: CTR - two people involved - report both? WonderWoman
J2C Offline
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Big Brother knows and that's a...
It was done at the same time, at the same window from the same account? I'm on the fence, but my gut says file the CTR as well.
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#1519501 - 03/09/11 06:46 PM Re: CTR - two people involved - report both? J2C
Princess Romeo Offline

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Where the heart is
I also say file CTR - check "Multiple Persons" and fill out a Section A on each of them, and fill out Section B with "conducted on own behalf" and check Box 32 for Negotiable Instrument Cashed.
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#1519507 - 03/09/11 06:50 PM Re: CTR - two people involved - report both? WonderWoman
fnbgal Offline
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CA
I'm curious to see what others think because I would not have filed a CTR.

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#1519509 - 03/09/11 06:52 PM Re: CTR - two people involved - report both? fnbgal
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Unless I had knowledge that they did NOT both benefit I would file a CTR on both just because of the way they structured the transaction, meaning structured in the literal and regulatory senses of the word.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1519525 - 03/09/11 07:03 PM Re: CTR - two people involved - report both? Kathleen O. Blanchard
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
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gone fishin'
So of course our staff didn't ask them any of these questions (are you both benefitting ... etc ...)
_________________________
My opinions are my own, and not that of my employer.

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#1519535 - 03/09/11 07:12 PM Re: CTR - two people involved - report both? WonderWoman
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Whatever their intent, they created an appearance of colluding together to get the check cashed and distributed to them without a CTR being filed. It is so convoluted that I would file the CTR and the SAR.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1519564 - 03/09/11 07:40 PM Re: CTR - two people involved - report both? Kathleen O. Blanchard
WonderWoman Offline
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WonderWoman
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Posts: 2,108
gone fishin'
I agree
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