File CTR or not

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.
Posted By: Doug Hendrickson

Re: File CTR or not - 09/12/14 03:28 PM

$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.
Posted By: Doug Hendrickson

Re: File CTR or not - 09/12/14 03:38 PM

Your core processor doesn't file CTRs, thank god, you do. It is CTR-able.
Posted By: Pat Patriot Act

Re: File CTR or not - 09/13/14 01:31 PM

I feel like joining the chorus here. A $10,000 cash deposit with a $100 currency exchange: file the CTR.