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#1772436 - 01/04/13 02:44 PM CTR Phamphlet
BSAChick Offline
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Joined: Oct 2005
Posts: 94
Illinois
For those of you that mail out the CTR phamphlet to customers that are structuring do you send a letter to accompany it or do you just send the phamphlet and hope they get the hint?
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#1772444 - 01/04/13 02:54 PM Re: CTR Phamphlet BSAChick
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I've seen instances in which a bank inserts the pamphlet with every business cycle statement (and documents the fact that it did it) and those in which a bank targets specific customers with the pamphlet. In the latter cases, I have always seen some sort of form letter go out with it that suggests it's being sent to the customer to provide information that the bank believes the customer will find helpful and provides contact information for any questions.
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#1772460 - 01/04/13 03:09 PM Re: CTR Phamphlet BSAChick
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
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Next to Harvey
I'm not nuts about the cover letter; the pamphlet speaks for itself.

However you do it, keep a record of the fact you did so. If you file a SAR on the customer for structuring note the distribution dates for the pamphlet in the narrative. LEAs love the idea that the customer cannot say 1) he did not know what structuring was and 2) he did not know it was illegal.
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#1772502 - 01/04/13 04:06 PM Re: CTR Phamphlet BSAChick
BSAChick Offline
Member
Joined: Oct 2005
Posts: 94
Illinois
Thank you!
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