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Would a CTR be required for 10,025.00?

Answered by: 
John Burnett
Brian Crow

Question: 
Member A has two accounts. In one day, Member A withdraws 10,000.00 from the first account. Later that day Member B, husband of Member A and joint owner of the second account, withdraws 25.00 from the second account. Would a CTR be required for 10,025.00?
Answer: 

Answer by Brian Crow: It is commonly held that all joint owners benefit from a deposit to a joint account as any owner would have access to the funds. However, withdrawals are another matter. FinCEN has not published any guidance on the subject of withdrawals. A CTR is triggered by the same individual conducting transactions exceeding or benefiting from transactions exceeding $10,000.00. In this scenario, neither individual conducted more than $10,000.00 so you are left to decide if one or both members benefited from each of the withdrawals. If you conclude that they did, then file a CTR. If you determine that they did not, do not file.

Answer: 

Answer by John Burnett: I will only add to Brian's analysis to suggest that I'd find it hard to assume that Member B's $25 withdrawal is significant enough to have been made on behalf of both Member A and Member B.

First published on BankersOnline.com 9/19/11

First published on 09/19/2011

Filed under: 
Security
Filed under security as: 
FinCEN
IT

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