CTR filing on another bank

Posted By: moola741

CTR filing on another bank - 12/27/19 02:27 PM

We had a local bank come and get over $10,000 in cash from us. This does require a CTR correct? There seems to be some discussion that because it is another bank one is not needed. Should this be a habit then they could be exempted but I do believe this is a one time thing and one needs to be filed.

Thank you in advance of your comment.
Posted By: edAudit

Re: CTR filing on another bank - 12/27/19 02:50 PM

https://www.fincen.gov/resources/st...termining-eligibility-exemption-currency

Phase I

Banks operating in the U.S.
Posted By: BrianC

Re: CTR filing on another bank - 12/27/19 03:05 PM

Unlike Phase II exemptions, Phase I's do not require that the customer exceed five reportable transactions in the previous 12 months.
Posted By: RockChucker, CAMS

Re: CTR filing on another bank - 12/27/19 04:56 PM

Banks thankfully are exempt.
Posted By: Richard Insley

Re: CTR filing on another bank - 12/27/19 05:20 PM

Phase I exemptions are declared by the regulation. All you need to do is verify that the customer lies within one of the Phase I definitions. If an internal discussion was deemed appropriate in this case, now's a good time to review the exemption regs and provide some training for everyone who could logically become involved in future CTR exemption determinations and administration.
Posted By: moola741

Re: CTR filing on another bank - 12/27/19 05:37 PM

Thank you for your input