CTR or no CTR

Customer A withdraws $10000 from her savings account in cash. Later the same business day, using a $100 bill, she deposits $60 into her checking account, receiving $40 cash back. Does the $40 cash back need to be aggregated with the $10000 from the savings withdrawal and a CTR filed?

IMO, no.

*ditto* to Just Jay

But I would definitely put this person on my radar ...

I'm curious as to why you wouldn't file a CTR. Didn't the customer technically walk out of the bank with more than $10,000 in cash when the two transactions are aggregated?

I would "technically" they walked out with $9640.

I do not view the $40 cash back out of the $100 as a withdrawl nor as a cach exchange. I see a $10k WD, and a $60 deposit.

I can see why some may consider the $40 cashback as a cash exchange out, but I do not.

Which ever way you choose to treat the $40, just be consistent with it going forward.

Our system would aggregate this as:

$10,000 cash out + $40 Cash out = $10,040
minus your $60 cash in - = $9980 - total cash out -

not reportable - but kind of odd.....

I do not think that you are supposed to "net" out the transactions. You add deposits, add withdrawals - if either one is reportable, you report such amount on a CTR.

As it turned out, the teller who processed the second transaction ($40 cash back from a deposit) was prompted by the system to complete the CTR. Our central office said it wasn't necessary.
Thanks to all for responding.

I would say it is necessary. You do not know for sure that the $100 was from the cash earlier in the day. She left the first time with $10000.00 and the second time with $40. I would say yes on the CTR.

Definately CTR.

I'll add my voice to the chorus that says you absolutely do not subtract the cash in from the cash outs to arrive at a net number. That's a strict no.

I could go either way on whether the $40 "change" is additional cash out. The odds of coming up with a similar scenario are slim, but I suggest deciding how your bank should have handled the day's transactions, and be consistent in the future.

For what it's worth, an additional thought: While thinking about odds, you should ask yourself whether the odds are greater of having this scenario questioned by an examiner if you file the CTR for $10,040 or don't file. And, if questioned, which option would be easier to defend. If you consider those questions honestly and practically, I bet you'd file.