Hello,

Scenario: Customer brings in $12,250 cash and buys two cashiers checks totaling $12,235. Then takes the extra $15 back.

Am I correct in thinking we would fill out the CTR as follows?

25 Cash In:

25d purchase of negotiable instruments - $12,235
25e currency exchange- $15

Total cash in $12,250

Nothing in 27 as cash out did not exceed $10,000

That is exactly what it should look like.

While I agree that this is technically correct, a part of me just has to shake my head since the characterization of that $15 has now engaged valuable resources that could be deployed in so many other productive ways.

I would like to re-visit the proposal I made about 10 years ago that we do away with CTRs and simply engage in "tape to tape" monthly reporting of cash transactions at the account level that aggregate over a certain dollar amount (to be determined) with a $100 margin of error. Then, no matter how many "structured" deposits a person might make, the aggregate will catch up.

Then, instead of frying brain cells in figuring out how to complete a CTR, which at this point is approaching the complexity of 1040 income tax return, we could focus our resources on analyzing patterns of behavior, including multiple accounts with smaller cash transactions as truly indicative of structuring.

Or - put another way - lets' pull the main work horse of BSA out of the 1970's and re-engineer it for 2020.