02/08/2010
If a husband withdraws $10k from branch(A) and within minutes the wife withdraws $9K at branch (B) is an aggregate CTR required?
09/28/2009
Does the Travel Rule apply to incoming wires?
08/17/2009
If an irrevocable trust is set up whom do we CIP, the trustees, the beneficiaries?
04/27/2009
Who do you need CIP on (the co-trustee, beneficiary(ies) and/or grantor) since an Irrevocable Trust is the customer for CIP purposes and the grantor is deceased at this point?
04/13/2009
Who is the beneficiary when a large cash deposit is made into an attorney's state bar client trust account and a CTR is required to be filed? The account uses the state bar TIN and the attorney refuses to divulge his client's information.
03/30/2009
Why is it that most banks that originate outgoing wire transfers require a physical address (no PO boxes) for the beneficiary? Is this a compliance requirement and if so, where is it established? I have looked at Reg J, the UCC, the BSA exam manual and the travel rule without much luck. The latter proved more helpful than the others, but still offered little justification for the requiring of the beneficiary's physical address. In this regard, the rule states that the originating bank is only required to retain "beneficiary information provided by the requestor" which may or may not include an address. Any help in determining how and/or why this no "PO box policy" was derived would be greatly appreciated.
03/23/2009
When completing a CTR for a deposit to a Totten trust account "John Doe Trustee for Sally Doe," who should be indicated as the beneficiary of this transaction on the CTR if John Doe's SSN was used to open this account? If a deposit requiring a CTR is made to a TXUTMA account "Sally Doe, Beneficiary TXUTMA, John Doe, Custodian," who should be indicated as the beneficiary on the CTR when Sally Doe's SSN was used to open this account?
12/15/2008
According to the Guru Q&A <a href="http://www.bankersonline.com/security/guru2007/gurus_sec121007b.html">"CTR on a Representative Payee Account"</a>, when a representative payee conducts a transaction that requires a CTR the Rep Payee and the Beneficiary should both be put into section A with the Rep Payee also in B as conductor. My supervisor doesn't agree and I need to explain why your answer is correct, but I can't find anything online. Why should the CTR be done the way it is described in the Q&A?
11/03/2008
What is the proper titling for a representative payee account for Social Security and what would the relationships be?
09/08/2008
A customer opened an individually owned CD and listed a beneficiary. The CD was opened with $13,000 in cash, so we will file a CTR. Does the CTR have to include the beneficiary?