CTR Exempt Customer

Posted By: Jennifer

CTR Exempt Customer - 01/24/18 02:23 PM

Two questions:

Same business owner makes deposits into two separate businesses - no co-mingling. Even though the businesses are not co-mingled, since the same person made both deposits - transactor - a CTR would have to be filed due to that fact, correct?

Second question - same scenario - pretending one of those businesses was CTR exempt - the bank would not report the CTR exempt customer, correct? The amount of the other business did exceed $10K.
Posted By: Cape Codder

Re: CTR Exempt Customer - 01/24/18 02:29 PM

BSA gal - assuming the total cash in on your first scenario is over $10,000, yes, CTR reportable since you have a common conductor. You'll also have a CTR on the second scenario since the amount of cash to the non-exempt customer exceeded the threshold. You won't include the cash for the exempt customer in your CTR.
Posted By: bcompliance

Re: CTR Exempt Customer - 01/24/18 06:11 PM

Agree with Cape Codder.