Cash ATM Deposits over the weekend

Posted By: Craney

Cash ATM Deposits over the weekend - 06/04/21 09:17 PM

I'm pretty sure I know the answer for this, but am having trouble on where to find the wording for the situation. But here's the situation: A customer deposited $5,000 cash on Saturday, $5,000 cash on Sunday and $1,500 on Monday through one of our ATMs. Since Monday was a holiday, it all got processed on Tuesday.

Since all cash transactions were processed on Tuesday and it is over the filing threshold, I believe that a CTR should be filed, am I correct? And if so, where can I find that info for future purposes?

Thanks in advance for the help!
Posted By: rlcarey

Re: Cash ATM Deposits over the weekend - 06/04/21 09:47 PM

https://bsaefiling.fincen.treas.gov/docs/XMLUserGuide_FinCENCTR.pdf

General Instructions
1. Who must file. Each financial institution (other than the U.S. Postal Service, for which there are separate rules)
must file a FinCEN CTR for each deposit, withdrawal, exchange of currency, or other payment or transfer, by,
through, or to the financial institution which involves a transaction in currency of more than $10,000. Multiple
transactions must be treated as a single transaction if the financial institution has knowledge that they are by or
on behalf of the same person and they result in either currency received (cash in) or currency disbursed (cash out)
by the financial institution totaling more than $10,000 during any one business day. For a bank, a business day is
the day on which transactions are routinely posted to customers’ accounts, as normally communicated to
depository customers.
Posted By: Richard Insley

Re: Cash ATM Deposits over the weekend - 06/05/21 05:46 PM

Report what your records will show if questions are asked a year from now. This customer's account will reflect a single deposit of $11,500 on Tuesday. Yes, there are additional details, but to research them, you will have to start with the $11,500 entry.
Posted By: John Burnett

Re: Cash ATM Deposits over the weekend - 06/07/21 03:03 PM

In any bank that I'm familiar with, the three deposits will appear separately on the customer's statement and the transaction record for the account, albeit on the same business day, Tuesday, June 1. The cash entries to the bank's general ledger from those deposits will also post on June 1. The text underlined in Randy's citation from the CTR instructions is what you need.

The combining of the deposits that Richard alludes to is likely to appear in a system report of multiple cash transactions to the same account or to the accounts of the same customer. That is the one place you will likely see the $11,500 amount.
Posted By: Craney

Re: Cash ATM Deposits over the weekend - 06/07/21 03:34 PM

Thank you guys for all your help with this! That's what I was thinking as well, and this gives me the backup.