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Boxes to Check Filing a CTR

Answered by: 
John Burnett

Question: 
If a customer cashes a check of over $10,000 on his own account at our bank, is it a problem to check both box 32 and 34 on the CTR? It is a withdrawal and a negotiable instrument is cashed, so it seems that by checking both boxes it makes it more clear as to what the customer actually did, rather than just checking box 32, which could imply he cashed a not-on-us check. FinCEN told our auditor it was not really a problem, but our independent review person says it is not correct. What is your opinion?
Answer: 

I agree, and it's not technically wrong. In fact, my source at FinCEN told me (it's not published, as far as I know) that law enforcement would prefer to see the negotiable instrument box checked in that scenario (with or without the deposit/withdrawal box checked) because they like to know when negotiable instruments are involved. Of course it would be incorrect to check the negotiable instruments box if the withdrawal is made using an in-house withdrawal form.

First published on BankersOnline.com 7/05/10

First published on 07/05/2010

Filed under: 
Security
Filed under security as: 
FinCEN
IT

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