CTR Question Night Drop + currency exch no conduc

So, we have night drops well over $10,000.00, no problem. Add 2 small currency exchanges for the same business
done through the drive through same day, no conductor info gathered and the branch does not remember. Should we use aggregated transactions on the CTR?

Here's the guidance from the CTR FAQ's:
27. When do you check the “Aggregated transactions” box (Item 24)?

Filers should check box 24e “Aggregated transactions” (along with any other box applicable in Item 24) only in the following circumstance: 1) the financial institution did not identify any of the individuals conducting the related transactions, 2) all of the transactions were below the reporting requirement, and 3) at least one of the aggregated transactions was a teller transaction. If the aggregated transactions being reported included only deposits made via a night depository, the financial institution would not check “Aggregated transactions” as none of the aggregated transactions were a teller transaction; instead, the financial institution would check Item 24 “Night Deposit.” A “teller transaction” would include, but would not be limited to: the deposit or withdrawal of currency by an individual at the teller window, an individual making a loan payment with currency at the teller window or, an individual exchanging currency at the teller window. The option “Aggregated transactions” is not the same as Item 3 “Multiple transactions,” which can involve transactions that are above the reporting requirement.

For example, if there were four $3,000 deposits made into ABC Restaurant’s business account in one business day, and the filing institution did not identify any of the individual transactors, and at least one of these deposits was made via a teller transaction, the filing institution would complete a Part I on ABC Restaurant checking Item 3 “Multiple transactions” and checking “Aggregated transactions” in Item 24.

However, if the filing institution identified the fourth individual transactor, as a result of knowing the transaction takes ABC Restaurant over the $10,000 threshold, then the filing institution would complete a Part I on ABC Restaurant checking Item 3 “Multiple transactions” and a separate Part I on the fourth individual transactor. The filing institution would NOT check “Aggregated transactions” in Item 24 due to the fact that it identified one of the transactors.

If there were four $3,000 deposits made into ABC Restaurant’s business account via any combination of Armored car (FI Contract), ATM, Mail Deposit or Shipment, or Night Deposit, i.e., without any of the deposits being made via a teller transaction, the Aggregated transactions box should not be checked. Instead, the other boxes in Item 24 should be checked to the extent that they are applicable.


The compressed version that I distribute to my CTR filers is:
1. Any transaction was over $10,000
2. At least one of the transactions was a teller transaction
3. The Bank was unable to identify the individual(s) conducting the related transactions

If those 3 criteria are met, then and only then would you use the aggregated box. From your circumstance I would need clarification regarding the night drop before making my judgment; was the $10,000 from the night drops in a single transaction, or multiple transactions? If there was a single night drop over $10k within that total, then you would not be able to use the aggregated box. If you have multiple night drops under the $10k mark and also have the currency exchanges that are under $10k which are teller transactions, you would use both the Night Drop and Aggregated boxes as far as I'm reading into it.

Shouldn't your first item read "None of the cash transactions was for more than $10,000"?

Multiple night drops, none over $10K, plus the couple of small currency exchanges via the drive through. I think we just spotted in the instructions the line that says 'Check all that apply', so I do think now we should use both.

Sorry, yes John it should & does read "none of the cash transactions was for more than $10,000". Guess that's what I get for posting before I've had coffee!

On one CTR we neglected to check "night deposit" ( this was found during an audit). Is it REQUired to file an amendment to the CTR? we will file but being able to counter the error citation with auditors will give us a zero exception audit. I have looked at FINCEN guidance ( have not called them) but can see nothing that could answer question.

The CTR is inaccurate, of course you have to file an amendment now that you know.

As far as zero exceptions, if this is all they found and this appears in the audit report as a finding that requires a management response, find new auditors next year.

CTR filer marked Aggregated transaction, and filed, but we had a conductor listed for all the transactions. This was done in error and was not found before filing. We did not receive an error from the FinCEN e-filing system.When I conducted an internal audit of the CTRs filed by the department, I found this error. Do we need to amend the CTR to remove the checkmark?

The only folks who can tell you no amendment is necessary work for FinCEN. I can only tell you that this amendment would be a waste of time... Checking the box was a pure error in completion and had no effect on the information provided.