Answer:
Whether or not you need to record information on Mom depends on how much cash was involved. If the transaction falls in the range of $3,000 to $10,000 inclusive, the record you are required to make concerns the individual who purchased the check, not necessarily the remitter. Sally Jo is the individual who brought in the cash and completed the purchase, so you have to collect the information about Sally Jo, who is a non-depositor, that is required for the recordkeeping rule. If the cash amount (including any cash received for your service fee) exceeded $10,000, you have to file a CTR, naming Mom as the person on whose behalf the transaction was conducted (Section A) and Sally Jo as the conductor (Section B).
First published on BankersOnline.com 8/30/10
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