05/28/2012
We have an armored car service that is acting as an agent for 3 different area businesses and delivering their deposits to the bank. We know that the transactions are CTR reportable over $10000, as they share the same transactor and that the July 2009 FinCEN Guidance indicates that we would need to gather the transactor's personal detail (not just mark Armored Car), but...Is there anyway to exempt the Armored Car company from CTR reporting? (We can't think of one, but we are looking at 50+ CTRs a year that would need manual merging in our processing system.)
04/09/2012
During the Top Gun 1st day session presentation from Tom Fleming @ FinCEN, the subject was brought up about bank customers who individually contract with armored car services instead of using a bank contracted service are required to provide conductor information for the CTR form. We have two customers who use a national armored car service which also happens to be the same service that the bank has contracted with. When the monies are delivered to the bank for these two individual customers by the armored car driver, they are refusing to provide their personal information as the conductor. We circled back around to the national armored car representative for our bank and they are stating that they don't feel that the armored car driver should have to provide their personal information as they work for the armored car company and not the individual customer who is receiving credit. So the question is, do we refuse to accept further deposits from a long time customer because of this issue? Has FinCEN provided any further communication regarding this situation? I would imagine we are not unique to this situation, however, as I stated above, these two customers are using a nationally known armored car service, not a company that is not well established in this type of service. Any and all information would be greatly appreciated.
02/27/2012
When considering a CTR exemption status for a privately owned business customer, is there any guidance for making a determination as to whether the business engages in 50% or more activity that would prevent the customer from being exempted?
02/20/2012
How do I fill out Section A and Section B CTR form for a sole proprietorship?
10/03/2011
We have an account with a joint owner and only one of them is making a deposit/withdrawal over $10k. Is this always considered a multiple person transaction and we need the info on both for the CTR?
09/19/2011
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?
09/19/2011
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?
07/18/2011
As a community bank, we do not open accounts for MSBs due to the risk. However, we have several businesses that are agents of MSBs such as Sigue Corp, RIA Financial, Moneygram, and Western Union. Is the MSB responsible to see that these businesses are meeting reporting requirements, or are we to enhance our due diligence in overseeing these accounts?
02/14/2011
Is a CTR required to ship excess cash to the Federal Reserve?
11/08/2010
I recently learned that the bank filed a CTR on a customer who had been exempted from reporting. The CTR was filed almost a year ago, and since that time there have been many transactions that were not reported because of the exempt status. Would proper handling include filing late CTRs for all eligible transactions since the CTR that was submitted in error, and then resubmitting an exemption form to reinstate the status as exempt?