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#2178727 - 05/18/18 04:14 PM CTR-to file or not to file
Couples Offline
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Joined: Apr 2009
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The Igloo

We are at odds as to whether to file a CTR on the below scenario. Can anybody give some guidance? Thanks!

We have two Customers:

One is a Corporation, name is Martin’s Markets, Inc. and the President and Signer on the account is Patrick Martin who is also President of the Corporation. On June 7, 2018, multiple transactions totaling $9010 cash was deposited into their checking account via night drop (conductor unknown).

The second one is a sole proprietor dba Martin’s Drive Thru owned by Patrick Martin. On June 7, 2018, multiple transactions totaling $6765 cash was deposited into that checking account via night drop (conductor unknown) of which Patrick is, of course, the signer.

Question: Would we file an aggregated CTR on Patrick? Would any CTR be filed?

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#2178757 - 05/18/18 05:25 PM Re: CTR-to file or not to file Couples
rlcarey Online
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rlcarey
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Galveston, TX
Is there evidence that Patrick is comingling personal and business funds?
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#2178760 - 05/18/18 05:27 PM Re: CTR-to file or not to file Couples
Couples Offline
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The Igloo
No. There is not.

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#2178764 - 05/18/18 05:35 PM Re: CTR-to file or not to file Couples
rlcarey Online
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Then you have two separate transactions.
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#2178768 - 05/18/18 05:43 PM Re: CTR-to file or not to file Couples
Couples Offline
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The Igloo
Thanks, Randy! That was my educated guess. Glad to know I am on the right track.

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#2178832 - 05/18/18 08:07 PM Re: CTR-to file or not to file Couples
John Burnett Offline
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John Burnett
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Cape Cod
You'd file if you knew that Patrick made all the deposits. But since the corporate deposits went down the night chute, you don't have conductor info.

Heaven help us if we start installing cameras at night drops to ID who's holding the bags.
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#2193612 - 09/24/18 08:41 PM Re: CTR-to file or not to file Couples
DoS Offline
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DoS
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one state over
On a similar note … an owner of a phase II exempt business comes in and deposits $12,000 into business and $1200 into personal at the teller window. Since the business is exempt would the funds still count towards the personal transaction? I am pretty sure I am overthinking this.
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#2193634 - 09/25/18 01:03 PM Re: CTR-to file or not to file Couples
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,694
Illinois
The exempt transaction doesn't exist as far as CTR aggregation is concerned. No CTR required on the $1,200 personal deposit.
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