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CTR Filed for Withdrawal of Retirement Funds?

We have a member who withdrew cash three weeks in a row, same branch different tellers. The withdrawals weren't over $10,000, but total of withdrawals is $18,000. Can we file a CTR as multiple transaction? The member is retired and was withdrawing some of his retirement funds.

Answer by Jim Bedsole:A CTR would only be required if the transactions were conducted by or on behalf of the same person on any one banking day. Since you say the transactions took place in three different weeks, a CTR would not be required. Depending on the circumstances, you could potentially have an issue with structuring, and thus a SAR filing requirement, but I'd need to see more information other than what's in this post to reach that conclusion, but definitely, no CTR is needed.


Answer by John Burnett:I'll go one step further. It would simply be wrong to file a CTR for the transactions you have described.

First published on 8/16/10

First published on 08/16/2010

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