CTR - Aggregation and Business Days

Posted By: NeBanker

CTR - Aggregation and Business Days - 05/23/11 02:06 PM

If we have customer deposit $5500 on a Saturday(Mondays business) and then deposit $6000 first thing Monday we would file a CTR on them for the aggregated $11500 on Mondays business correct?
Posted By: BrendaC

Re: CTR - Aggregation and Business Days - 05/23/11 02:11 PM

Absolutely, same business day with over $10k in cash deposits. I would also look at nature of deposits to determine whether they may have been structured to avoid a CTR.
Posted By: ACBbank

Re: CTR - Aggregation and Business Days - 05/23/11 02:17 PM

Those transactions need to be aggregated for CTR purposes. As Brenda said, I would also look into the account history to see if the customer is attempting to structure the deposits to avoid a CTR from being filed.
Posted By: NeBanker

Re: CTR - Aggregation and Business Days - 05/23/11 02:20 PM

Thanks for the conformation, and yea they are being structured. The customer actually told our teller that’s why she split the deposit.
Posted By: BSABecky

Re: CTR - Aggregation and Business Days - 05/23/11 02:35 PM

Originally Posted By: NeBanker
Thanks for the conformation, and yea they are being structured. The customer actually told our teller that’s why she split the deposit.


*headdesk*