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Info on Customers with CTR Exemption

Question: 
We continue to collect information regarding deposits over $10,000.00 from our customers who have a CTR exemption. Is this necessary?
Answer: 

by John Burnett:

Well, yes!

You need to do an annual verification that each of your customers for whom you have filed a DOEP (form 110) still qualifies for the exemption. For "Phase 2" exemptions, that includes verifying they had the requisite number of otherwise reportable cash transactions during the year. You can do that by keeping track of each time they would have had a CTR filed but for the exemption. Or you can go back over the year's cash deposit reports to see how many times they exceeded $10K. If you have a system report that can do that lookback for you, you might not need to accumulate information during the year.

Answer: 

by Brian Crow:

John answered the question asked. "Do we collect information...from our customers."

In the event the intent of the question was to ask, "Do we collect information from our customers' employees who make deposits?" then your institution should make a risk based decsion whether it needs the information. It's not needed to complete a CTR, but you may decide from a due diligence perspective that you also want to monitor those individuals making cash deposits in case they are also making deposits to their personal accounts or other business interests to determine if the overall volume of cash coming in from those individual(s) makes sense.

First published on 10/31/2021

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