Aggregating Debits & Credits For CTR Purposes

Answered by:

Question:

If a customer comes in and deposits cash of $5,698.00 in one account and that same day makes a withdrawal of cash from a different account belonging to that same customer for $5,000.00. Those two amounts aren't added together for CTR purposes are they?

Answer:

Answer: No. A CTR should not be filed for this situation. Let me quote part of a similar Q&A for you. This comes from the FDIC's Financial Institution Letter 7095, October 12, 1995:QUESTION: Should "multiple transactions" be aggregated?

Answer:

Answer: Yes, to report multiple transactions, all the individual transactions of which the financial institution has knowledge must be aggregated, which means that debits must be added to debits, and credits must be added to credits. If the cash debits or the cash credits totals exceed $10,000 in a business day, a CTR is required. If debits and credits each exceed $10,000, they can both be reported on a single CTR. Do not mix debits and credits by offsetting one against the other, that is, do not mix cashin transactions with cashout transactions.

Notice that debits are added to debits and credit are added to credits for the $10,000 limit. Never add debit to credits.

First published on BankersOnline.com 7/15/02