CTR withdrawal and MI purchase

Posted By: Jodi

CTR withdrawal and MI purchase - 05/24/17 05:11 PM

I'm filling in for the BSA Officer and need CTR help! If a customer withdraws $20,000 in one transaction, then in a separate transaction uses $2300 of that cash to purchase a cashiers check, is this the correct way to complete the CTR: $20,000 shown as CASH OUT; $2300 shown as CASH IN; List Account Number Affected; Select option Negotiable Instrument Purchased? If not, what corrections are needed?
Posted By: thomasj

Re: CTR withdrawal and MI purchase - 05/24/17 05:16 PM

The CTR would only be filed for the $20,000 cash out since the cash in amount did not exceed $10,000.
Posted By: rlcarey

Re: CTR withdrawal and MI purchase - 05/24/17 05:16 PM

If the cash in does not exceed $10,000, you have no obligation to report it.
Posted By: Jodi

Re: CTR withdrawal and MI purchase - 05/24/17 05:22 PM

Thank you to both of the responders!
Posted By: Midwest BSA

Re: CTR withdrawal and MI purchase - 05/24/17 06:19 PM

$3,000 is the threshold that you'd log the purchase of a monetary instrument (internally) - maybe that's what you're thinking of?
Posted By: LC Northeast

Re: CTR withdrawal and MI purchase - 06/01/17 06:19 PM

Did the customer leave the branch with $20,000 and return with $2,300 to purchase the MI? If that is the case then yes I agree the CTR should be filed as a $20,000 withdrawal.

However, if the customer didn't leave the branch with $20,000 and only left with $17,700 ($20,000 minus the purchase of the official check), shouldn't the CTR have been filed for $17,700 as that is what the customer left with?