A question about CTR exemptions. We have a customer who owns a bowling alley. He has the bowling lanes, the pro shop, the snack bar and a children's party room organized as four separate businesses, each with its own tax ID number. Invariably, deposits are made for all the businesses at the same time, so they are aggregated and reported on a CTR when the cash amounts exceed the 10K threshold as the same individual makes all the deposits. Is it possible to exempt these businesses even though individually none of them ever exceeds the 10K reporting threshold? I assume that we would have to file a separate exemption form for each business.
By FinCEN Office of Regulatory Policy
I participated in a recent seminar where BOL Guru Dana Turner was the presenter. He mentioned that there might be a conflict of interest if the bank's Security Officer was also a director. I am in that position and I have discussed this with the Board/Executive Committee and was told today that they had talked with our bonding company and were told this was not an issue. What is the rational for ensuring that our Security Officer should be an employee, rather than a director?
Can a foreign person without a Social Security Number have an interest bearing account? How would you report the interest earned?
Are Federal Credit Unions automatically exempt?
If a government agency (DEA) sends a representative to purchase an Official Check do we need to get the identifying information on the government representative?
When opening an account with a rep payee, what is the correct way to title the account and who would be considered primary account holder?
What are the risk of setting up a Qualified Income Trust account for the financial institution?
If an IRS Special Agent purchases a cashier's check payable to the Department of Treasury with more than $10,000 in cash, is a CTR required?
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.)