I need clarification regarding Section B , boxes c (Night Deposit/ATM) and d (Mutiple Transactions) - Scenario: Box 1c (Multiple Transactions) is checked under Section A and boxes c and d are checked under Section B with the remaining section completed. When the aggrgated transactions consist of both night deposit/ATM and lobby transactions, is it appropriate to check the box 1c under Section A and boxes c/d under Section B, particularly when items 15 - 25 are fully completed? I did search the Navigational Aid for an answer to my question, but didn't see a Q/A for this situation.

You always check box 1c if you have more than one transaction. The boxes in Section B are to indicate why you may not be providing any or all of the identifying information on individuals who actually conducted the transactions.

For example, if you have four transactions (1 in person by Joe and 3 by night deposit), you should provide Joe's information in Section B and check box c to indicate the remainder of the transactions were by night deposit. You would not check box d because it does not apply in this scenario as a reason the identifying information is not complete.

If you had a scenario where you have three deposits which total a reportable amount of $11,000, but each one was under $10,000, that is when you would check Boxes 1C and D. This tells the IRS that you don't know who conducted one or more of the transactions because they were under the reporting threshhold. We often have these with our fast food restaurants and convenience store customers.

I hope this makes sense!

Box 1c is used whenever you are combining multiple transactions on one CTR. That one, thankfully, is pretty easy.

Boxes c and/or d in Section B of Part I (why didn't they give this group of boxes an item number like they did item 1?) are used to explain why information in Section B is missing or incomplete. That's not such an easy call.

Let's say that one of the multiple deposits comes in at the teller window, and you know that you'll be filing a CTR, so you get all the info needed for items 15 - 25. Later, another deposit comes in to the same teller (for less than $10K in cash), and the same person brings it in. You will check box 1c, but not box I-B-d, since there's nothing missing or incomplete in Section B. But if one of the deposits included on your CTR is from the night depository, and you don't know who made the deposit (usual case), then box I-B-c gets checked, even though you complete items 15-25 for the person who completed the over the counter transaction. You're telling FinCEN you don't know who made one of the deposits.

Another scenario: Teller A takes an $8,000 cash deposit from XYZ company at 9:30 a.m. Two hours later, Teller A gets another $7,000 cash deposit to XYZ company's account, and forgets the first deposit. So far, no CTR has been prepared. The next day, internal reports flag the deposits and require that a CTR be made up for the multiple deposits. Box 1c gets checked. Whether box I-B-d gets checked depends on whether Teller A recalls who made the deposits, and whether the bank has the needed information to complete Section B. If two "runners" were involved, and Teller A has all the needed info to complete items 15-25 on both (from prior CTRs or elsewhere), no check mark in box I-B-d. But if the bank is missing any of the required Section B data for either runner, fill in as much info as is known, and check box I-B-d.

You would check 1C to indicate that multiple transactions apply to the filing of the CTR. You do not check any of the "excuse" boxes in Section B unless that is the reason you have left Section B, Items 15 through 25 blank or incomplete. You have said that Section B is fully completed, so do not check blocks c or d under Section B.

My opinions are my own and not those of my employer.

The previous answers were correct. You need to mark all boxes that apply. If money walked in the bank with a person and you have the information, and money also came through the night drop, you need to mark that as well as filling in boxes 15-25. These boxes are not "excuses", they are telling the IRS how the money was brought into the bank.

The instructions do not say "check the box that applies for how the money was brought into the bank". Boxes c and d are reasons why you may not have all of the information required for Section B. If one of the transactions was through the night deposit and the identity is unknown, then you don't know who made one of the deposits, even though you have completed items 15 - 25 for the person who conducted the other transaction at the teller window. And, yes, I would also check box I-B-c based on that reasoning. In that regard, I stand corrected. Thanks,

Ann

My opinions are my own and not those of my employer.

Ann, you are right on the mark. Boxes a through e in Section B are "excuse" (perhaps some will prefer "explanation") boxes. They don't get used at all unless you either don't know who conducted one or more of the transactions or you don't have all of the information about a person who conducted one or more of the transactions because it was not a face-to-face (teller window) event.

As I said above, even if one of the deposits was a night deposit, if you know who did it (you happened to see it occur), you may have all the info you need to complete items 15-25 about that person. Unlikely, yes. Impossible, no.

Those of us who have been around a while may remember that the instructions for the old CTR used to suggest we had a duty to try to learn who did the night drop, and record the information. FinCEN wisely did away with that instruction when revising the CTR format. Perhaps they realized the futility of the rule?

John, thank you for the back-up. I started out at a small community bank in Union, SC, which has grown tremendously, but still exists. It would not have been unusual to know the identity of someone making a night drop and as you also remembered, back then we made attempts to find out the identity as well. Things have changed, but if I had the information, I would fully complete Section B and would not check one of the "explanation" boxes to describe how the money was brought into the bank.

My opinions are my own and not those of my employer.

This thread serves as a good reminder that we need to be watching these boxes carefully. The daily cash report I receive identifies each transaction separately. I try to look at the individual transactions to make sure we are accurately completing our CTRs. If a transaction is conducted for more than $10,000, I know to look for a specific person's information in Section B or the night deposit box to be checked. If a branch sends in a CTR with the multiple transaction box checked in Section B, someone isn't doing their job!

The above reply is not "Anonymous" - I didn't realize I was not logged in. I tell it to remember me, but sometimes it doesn't. Maybe because I switch back and forth between work and home computers. Thanks.

Ann

It seems like, if a poster disagrees with an answer, the person who gave the answer gets offended. You all seem to be saying the same thing and filling out the form the same way. Just stating it differently. Can we all just agree to disagree on how to state it. If I'm not mistaken this same senario came up in another post about a month or so ago.

Please no take offense because none was intended. I have noticed this in other posts regarding CTRs as well. We are all just here to help each other.

I am anonymous today because my computer does not seem to want me to be able to log in. Ahhh! the wonderful world of computers. Love to use them when they work but tired of scratching my head to figure out why I can do something one day and not the next. Same computer, same programs. Hmmm.

I've got to say that I didn't read in any of the messages on this thread that anyone was offended. Maybe you could clarify a little what offense you're referring to Anon72?

I think my reply backing Ann up may have come across as a little "uppity." I get that way, sometimes, as my wife can attest, and I apologize if that's how it was perceived. It certainly was not my intent.

At least my wife can give me "the look" when I'm waxing "uppity."

John, I appreciate the genuine contribution that you and everyone makes to BOL. In reply to "if a poster disagrees with an answer, the person who gave the answer gets offended" - that would be me he's referring to since the poster disagreed with my answer and I responded. So, honestly, I was not offended, didn't think I sounded offended, and apologize if the perception was otherwise. Take away my internet access and my compliance manuals - NO! please - throw me in the briar patch with the BOL gurus!

My opinions are my own and not those of my employer.