Thread Starter: Anonymous
Title: Re: Another basic CTR Question
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Aggregation. I know the rules state that "if the bank has knowledge" of certain transactions that trip a CTR, then we file. And "Having knowledge" essentially means our software captures the data for the report. But does the law say if the bank is using software to capture CTRs, that the software must capture those cases when one conductor handles several different company transactions??? The only knowledge we have is that teller might put 2+2 together and notice that these five deposits to different companies is more than $10,000. What if they don't recognize it? Is the bank obligated to use their software to aggregate based on the Conductor's SSN??
If this is in a FAQ somewhere, I sure haven't seen it.
Thanks.
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