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CTR on Night Deposits & In-person Deposits

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Question: 
Deposits are made at the night deposit (same day, same branch location) for a business owner that has 4 separate TINs. If these deposits are over $10,000.01 when aggregated should a CTR be filed? There are times when this customer will have deposits in the night drop for her multiple businesses and she may come in and conduct additional transactions for one of those businesses (cash below the reporting threshold) would we complete the CTR aggregating both the night deposit and in-person deposits?
Answer: 

If all of the night deposits are in the same night bag or envelope, they clearly are made by the same individual. That would require aggregating the cash in those night deposits to determine whether a CTR should be filed. If you are certain that the owner of the business makes all such deposits, list her information in Section B of the form (even if they are in separate bags). If the owner comes in to transact further business involving cash on the same business day, you should combine the in-person transactions with those in the night drop.

First published on BankersOnline.com 7/02/07

First published on 07/02/2007

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