Posted By: Calmeida12
File CTR or not - 09/12/14 03:21 PM
A business customer hands $10,100 in cash to a teller. On the deposit slip, he only wants deposit $10,000 and takes the $100 in change. Would that trigger a CTR? Is it what he hands in or what was actually deposited? Thank you.
Posted By: Midwest BSA
Re: File CTR or not - 09/12/14 03:26 PM
I would say yes. $10,000 cash in and then $100 change order. Because your teller is actually handling $10,100, which is over the CTR threshold.
$10,100 crossed the counter from the customer to the teller. CTR should be filed. $10,000 deposit to account and $100 on one side of currency exchange.
Posted By: Calmeida12
Re: File CTR or not - 09/12/14 03:28 PM
That's what I thought too. Our core processor is telling us that since the actual deposit was only $10,000 and the remaining was a cash back to the customer, that it doesn't trigger it.
Posted By: rlcarey
Re: File CTR or not - 09/12/14 03:29 PM
Since when does a core processer know anything about compliance???
Posted By: John Burnett
Re: File CTR or not - 09/12/14 03:33 PM
Ditto that^^^. And I wouldn't count on the core processor to back you up if you're cited for not filing based on the processor's advice.
Your core processor doesn't file CTRs, thank god, you do. It is CTR-able.
I feel like joining the chorus here. A $10,000 cash deposit with a $100 currency exchange: file the CTR.