Banker's Compliance Consulting Blog

CTR Questions Clarification

Written by Amy Kudlacek | Sep 30, 2022 8:33:34 PM

It appears there was an inadvertent typo in one of the CTR question and answers we put out on September 28th, and we wanted to clarify.

The answer to the question regarding a $20,698 cashier’s check purchase included an example which illustrated the $5 cashier’s check fee being included in “25e”. This should have read “25d”. The example explained that if you were to include the $5 fee in the total amount of the cashier’s check purchased in 25d, then 25d would reflect a cashier’s check purchase for an amount other than what was actually purchased. This can create an issue with the bank’s records as they will not show a cashier’s check issued for $20,703 since the cashier’s check was only for $20,698.

Please see the correction below in red. We’ve also provided, a comparison of the options for reporting the $5 fee separately or as part of the cashier’s check.

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 $97 cash 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 25d, 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.

See the blog this question is a follow up to here - https://blog.bankerscompliance.com/en/ctr-completion-questions

Published
2022/09/30