Aggregate for CTR Purposes, II?

If you have multiple entities operating under different EIN numbers, but 98% of the time one person brings in the deposits for all entities, do you aggregate all those deposits because you have one person acting on behalf of all of those? Our system doesn't aggregate them, but the teller has knowledge that most of the time one person is bringing them in. We are manually adding those together to create a CTR. The other 2% of the time, an additional person may bring in one or two of those. Will we be in violation if we just always add all together and always file if over $10,000 when added together. It is really a manual process and would be more accurate to just always add all together, than hope we catch it. There is one owner who has ownership in all of the entities and he is the one who generally brings all deposits in, but there are those times that one of the other co-owners brings in one or two deposits.

It is always a violation to file a CTR that is not accurate.

I understand that, but we don't always know in the back office if another person brings in an additional deposit if the system doesn't capture who the transactor is when it is a small amount.

If you don't know the information, you should not aggregate based on who conducted the deposits. If you feel you have to know, then have your tellers gather the information.

Most banks do the following:

1. Large banks are now identifying anyone that makes a cash deposit.

2. Small banks know who these typical customers are and make it a point to identify anyone making deposits to these select customer accounts.

These customers go to the same branch or branches every day. What you are describing is basically laziness when it comes to the branch/tellers responsibility to properly identify transactors on transactions that the bank well knows are going to have to be reported.

Failure to have a proper communication channel between the branches and the central office that files the CTRs is not an excuse.

^^^This


At my bank we tracked "frequent flyers" by putting on an account level status code that prompted the tellers to identify the conductor regardless of the amount.

Another option may be to analyze the businesses pursuant to FIN-2012-G001 and determine if they are not operating independently. This will allow you to aggregate all cash activity regardless of conductor. A caution: you need more than common ownership.

Another option may be to analyze the businesses pursuant to FIN-2012-G001 and determine if they are not operating independently.

But this still does not alleviate the need to properly identify the conductors of the transactions.

I did not suggest that it relieves you of that responsibility. My point is that it may be logistically easier for the original poster to group the relationship in that manner if it can be deemed appropriate. That way, they can aggregate the cash under all circumstances, even if they were unable to identify a conductor on a transaction which would mean the difference between reporting all of the cash and not reporting any of the cash.

I agree with you that it's a best practice to implement systems that will identify every cash depositor, but as I'm sure you're well aware, there are plenty of core systems that don't have same day aggregation and plenty of banks that made a justifiable risk-based decision to set conductor ID thresholds.

It seems strange to me that in this environment your teller system does not have features to collect information regarding conductors. Has anyone asked your core provider about this?