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#2167915 - 03/13/18 07:38 PM CTR Cash Back Question
Believing... Offline
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Joined: Apr 2012
Posts: 346
In the mountains
We normally don't have cash-in/cash-back transactions, but I've had two in the last week. Both are loan payments with the borrower paying with a reportable amount of cash and getting less than $100 back in cash. I've read about showing the cash back as "other" and describing as a loan overpayment or using the currency exchange field. I've always thought that was simply ludicrous! So, I'm in my AML software (it's new) and it will not permit an amount less than $10,001 to be entered in "other." Next, I sign on to the e-Filing system, thinking I will have to file the report from there. Guess what, it would not accept the low-dollar figure there either. Is there another way to file these? Our teller system does not "net" the figures. I don't want to get dinged at our next exam.

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#2167925 - 03/13/18 07:52 PM Re: CTR Cash Back Question Believing...
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
my AML software (it's new) and it will not permit an amount less than $10,001 to be entered in "other."


Neither will the CTR on the e-filing system. If I gave you $11,000 in cash for a loan payment, it's irrelevant how much you gave me in change, as long as it did not exceed $10,000.
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#2167938 - 03/13/18 08:06 PM Re: CTR Cash Back Question Believing...
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Not sure why you can't enter $10,847 for the loan payment (25b) as a cash in and $53 as an in for a currency exchange (25e).
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#2167946 - 03/13/18 08:26 PM Re: CTR Cash Back Question Believing...
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,722
Illinois
They are trying to enter the $53 in item 26 to cover the cash out portion of the transaction. Since the cash out is less than $10,000.01, it can't be entered and is not applicable.
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#2168428 - 03/15/18 05:50 PM Re: CTR Cash Back Question Believing...
Believing... Offline
Gold Star
Joined: Apr 2012
Posts: 346
In the mountains
Ahh, the lights are on now! And yes, Brian, I was trying to enter the currency exchange in item 27 instead of the Cash In side. It now makes a little more sense. What I actually ended up though with was a reportable Cash-in and Cash-out transaction. First, the customer cashed a Loan Proceeds check for $10,500. I showed the negotiable instrument cashed in 27(d). Later that day he brought $10,400 in cash back and paid off one of his other loans ($10,338.87), getting $61.13 in cash back. On the Cash-in side I showed a payment of $10,338.87 in 25(b) rounded up to $10,339 and then show a currency exchange in 25(d) for the cash back - $61.13 rounded up to $62. Then I added a Cash-out currency exchange in 27(e) to show an aggregate amount for the cash-out side (cashed check + currency exchange). Is this correct? The rounding will cause the Cash In and Cash Out amounts in items 21 and 22 to be off by $1, which I think is okay.

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#2168688 - 03/16/18 06:01 PM Re: CTR Cash Back Question Believing...
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Fractional dollars amounts are always rounded up on a CTR and they do not have to add precisely to the total amount being reported.
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