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
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.
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.