It seems like we’ve had a lot of client questions lately regarding proper completion of a Currency Transaction Report (CTR). So, we thought we’d share a few with you.
See update here - https://blog.bankerscompliance.com/en/ctr-questions-clarification
Question: We have a customer that came in with $20,800 in hundreds. He purchased a cashier’s check for $20,698, paid a $5 cashier’s check Fee, and received $97cash back. Since the Cash In total was $20,800, how do I account for the $97 he got back? Also, do you include the cashier’s check fee in 25d (Negotiable Item Purchased) or use 25z (Other)?
Answer: Since the total amount of Cash In is $20,800, enter $20,698 for the cashier’s check in 25d (Negotiable Item Purchased); enter $97 in 25e (Currency Exchange); and $5 in 25z (Other) and specify “cashier’s check fee”. It’s possible the $5 could just be included in 25d, but we believe it’s best to follow bank records so that the transaction can be recreated down the road, if necessary. For example, if you include the $5 in 25e, the amount reported would be $20,703. If you need to go back later you likely won’t be able to find any record of a cashier’s check for that amount.
Question: When a non-customer cashes a check drawn on our financial institution, do we need to reference an account number in Part II Number 35? The only option would be to report the account number on the check but that does not pertain to the non-customer cashing the check.
Answer: You do need to report an account number and it would be the account number held at your institution on which the check was drawn. FinCEN’s CTR instructions state to Record the account numbers of all accounts involved in the transaction(s). We believe that the intent is to get information on any "on-us" accounts involved so the CTR can be traced back to the transactions within the bank's records.
Question: If a customer withdraws $500 from their account via an ATM after 2:00 on Friday (which is the cut off time for ATM) it posts to the account on Monday. On Monday, she withdraws $10,000 from her account. Do we need to file a CTR?
Answer: The CTR rules want you to report cash transactions in excess of $10,000 that occur on the same business day. While the transactions may have occurred on different calendar days, as far as bank records are concerned, they occurred on the same business day (Monday). So, yes, a CTR should be filed for $10,500.
See update here - https://blog.bankerscompliance.com/en/ctr-questions-clarification
If you want to learn more about proper CTR completion, be sure to check out our webinar, “All About CTRs”, which is available now OnDemand.
Published
2022/09/28
