Answer:
Many banks have obtained copies of a FinCEN-authored handout that gives appropriate answers to that and similar questions. The beauty of handing it out is that everyone gets precisely the same answer and the information has been approved by regulators as not rising to the level of assisting someone in structuring.
If you don't have this handout available, you can legitimately make the following factual statement: "We are required to complete a Currency Transaction Report for any cash transaction or transactions that exceed $10,000." If asked to say more, or if the member says something like "So, if I withdraw $10,000 exactly, you won't have to file a report," you repeat word-for-word, "We are required to complete a Currency Transaction Report for any cash transaction or transactions that exceed $10,000."
First published on BankersOnline.com 5/14/12
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