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CTR on Same Day $10K Cash Out & ATM Transactions?

Answered by: 
David A. Dickinson

Question: 
For CTR reporting purposes, if you have a single transaction for $10,000 cash out, and in addition to that, several ATM transactions that would put the total cash out for the day over $10,000 would a CTR be filed? I have never run across this type of scenario before, and I am unsure if ATM transactions are included.
Answer: 

Yes, if you have knowledge that a customer has withdrawn >$10,000 in cash, you should file a CTR combining ALL cash outs. This would include ATM transactions. Here's Q&A #22 from FIL 70-95: http://www.fdic.gov/news/news/inactivefinancial/1995/fil9570a.html

22. Question: Should "multiple transactions" be aggregated?

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 off-setting one against the other; that is, do not mix cash-in transactions with cash-out transactions.

First published on BankersOnline.com 07/04/05

First published on 07/04/2005

Filed under: 
Security
Filed under security as: 
ATM
Reporting

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