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When to File CTR for Reg E Dispute Over $10,000

At what point would a CTR be filed for a Reg E dispute claim which states that over $10,000 in cash was deposited in the ATM? At the time a provisional credit is posted to the customer's account or at the time the Bank decides to make the provisional credit permanent, which could be 45 days? What business date is then used for the CTR, date of deposit in the ATM, provisional credit date, or permanency decision date?

by Ken Golliher: If your bank's position is that no cash was received, your bank is never going to file a CTR.


by Brian Crow:

If you open the ATM and find the cash in a reject BIN, the CTR is the date the deposit was intended to be made. (The same answer would apply to a teller that miss keys an account number and accounting has to fix the transaction the next business day when working the unposted report.)

First published on 05/20/2018

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