Odd/Unique CTR Scenario

Posted By: Wildcat Rampage

Odd/Unique CTR Scenario - 04/04/18 12:19 PM

I'm working on a CTR and I'm arguing with myself, so I'd like other opinions please.

***I'm here before everyone else to get work done in peace, so I haven't had the opportunity yet to ask why we allowed this transaction to happen, but I expect the answer to be something along the lines of, "Because we're a community bank and the customer asked us to do that so of course we said yes."

John Doe and Jane Doe own a savings account.

Jane Doe called and requested a $10,000 cash withdrawal to be picked up by Anita Name.

An hour after picking up the $10,000 cash from Jane Doe's account, Anita Name came back to the Bank and withdrew $60 cash from her own account - thus she left the bank with $10,060 cash and a CTR is required.

I'm trying to decide if I should (absent discussing with branch personnel who have yet to arrive to shed light on the situation) complete Part I's for Jane Doe and John Doe. I can convince myself that Anita Name picked up $10,000 cash on their behalf - EVEN IF they were going to gift it to her simply because she saved them the trip to the bank to pick it up.

Normally on a cash out, I would - of course - only assign the cash to the person who picks it up (there would only be one Part I). However this feels like a unique case because a non-account owner with no signatory authority picked the money up.

But, I freely admit I might be thinking too hard about this.

On the other hand, when one person brings in 10 other persons' paychecks and a CTR is triggered, I follow the conservative path and complete 11 Part I's, so.....

As you can see, I've worked myself into a circle here. Any clarity will be greatly appreciated.

Thank you.
Posted By: Wildcat Rampage

Re: Odd/Unique CTR Scenario - 04/04/18 12:43 PM

A bit of context....

Jane Doe and Anita Name are twin sisters.

Jane gave the money to Anita so Anita could go to a neighboring state and bail Anita's daughter out of jail.

The purpose sort of sways me back to saying I should only have one Part I now, that it was all for Anita.
Posted By: bcompliance

Re: Odd/Unique CTR Scenario - 04/04/18 02:00 PM

I don't think John and Jane benefitted from the withdrawal, so I would not include them. I'd certainly keep documentation of the scenario with the CTR so when it gets pulled by an examiner in a year you can explain the situation and why they weren't included.
Posted By: Always In Training

Re: Odd/Unique CTR Scenario - 04/04/18 02:11 PM

When Customer A cashes 10 other people's paychecks here that are signed over to her - I only fill out 1 part 1 on the CTR. Customer A got the cash. Obviously, FinCEN basically said, do what you think you need to do here.

I wouldn't put Jane & John on the CTR either. To me, Jane didn't want to write sister a check, so she authorized the bank to release cash to her sister in similar fashion to writing her a check. Why do people do these things? I don't know. Maybe so John doesn't see a 10k check written to the sister? There are lots of motivations and I'm not asked to get motivation on a CTR.

We'd only file on Anita.