Do I file this CTR or not?

Posted By: McGruff

Do I file this CTR or not? - 10/23/06 07:18 PM

Here's the situation: Customer has a personal account, a business account, and a business loan. Customer comes in and withdraws $15,000 from his personal account and takes it over to his loan officer and tells her he wants to pay down on his loan principal. She tells him he's being silly and sends him back to redeposit the cash so she can ACH the $15,000 out of his account and apply it to the loan. He goes to a different teller, and deposits the cash into his business account (not the personal account it originally came out of), instead of going back to the same teller so he can delete the original transaction and return the unneeded cash to the vault. Neither of the two tellers knew about the other one and so didn't catch on to the foolishness. We didn't put 2 and 2 together until I looked at the CTR report the next morning. So, now I have two transactions, two accounts, and two tellers to deal with. Should I call this a wash and not file, or go ahead and file just to be safe?
Posted By: Lestie G

Re: Do I file this CTR or not? - 10/23/06 07:41 PM

I think I'd document it well, but not file. The cash didn't leave the bank, and it really was a wash.
Posted By: Sing A Little

Re: Do I file this CTR or not? - 10/23/06 10:20 PM

I would document the transactions, and not file the CTR. The only reason that the customer withdrew the cash in the first place was because he didn't understand the easiest way to conduct the transaction.
Posted By: Kelsey D

Re: Do I file this CTR or not? - 10/24/06 12:34 PM

I agree.
Posted By: MagicCity

Re: Do I file this CTR or not? - 10/24/06 01:12 PM

Agree.
No CTR.
Document the event.
Posted By: straw

Re: Do I file this CTR or not? - 10/24/06 03:12 PM

No CTR; when I train, I use the phrase "walk through the door". If the customer walks through the door with more than $10,000 in cash, a CTR is triggered.
Posted By: CantBeShocked

Re: Do I file this CTR or not? - 10/25/06 01:18 PM

NO $$ left the bank - you do nto file. Just document this one.
Posted By: McGruff

Re: Do I file this CTR or not? - 10/25/06 06:10 PM

OK, that's what I thought, but I sometimes get in trouble for thinking. Thanks, guys!
Posted By: Dip

Re: Do I file this CTR or not? - 10/25/06 06:17 PM

...and for documentation, all I'd do (it's what I do here) is write the explanation right on your CTR report and then initial and date.