{"id":1992,"date":"2020-02-13T18:14:38","date_gmt":"2020-02-13T18:14:38","guid":{"rendered":"https:\/\/albanknews.com\/?p=1992"},"modified":"2020-02-13T18:14:38","modified_gmt":"2020-02-13T18:14:38","slug":"compliance-qa-ctrs-and-aggregated-transactions","status":"publish","type":"post","link":"https:\/\/albanknews.com\/?p=1992","title":{"rendered":"Compliance Q&A: CTRs and Aggregated Transactions"},"content":{"rendered":"

Question:<\/strong><\/p>\n

Regarding CTRs, when there is an aggregated transaction, what are the requirements in order for the transaction to be considered an aggregated transaction?<\/p>\n

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Answer:<\/strong><\/p>\n

The bank would report as an aggregated transaction only if, 1) the financial institution did not identify any of the individuals conducting the related transactions, 2) of all the transactions were below the reporting requirement, and 3) at least one of the aggregated transactions was a teller transaction. All three requirements must be met.<\/p>\n

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  1. When do you check the \u201cAggregated transactions\u201d box (Item 24)?<\/em><\/li>\n<\/ol>\n

    Filers should check box 24e \u201cAggregated transactions\u201d (along with any other box applicable in Item 24) only in the following circumstance: 1) the financial institution did not identify any of the individuals conducting the related transactions, 2) all of the transactions were below the reporting requirement, and 3) at least one of the aggregated transactions was a teller transaction. If the aggregated transactions being reported included only deposits made via a night depository, the financial institution would not check \u201cAggregated transactions\u201d as none of the aggregated transactions were a teller transaction; instead, the financial institution would check Item 24 \u201cNight Deposit.\u201d A \u201cteller transaction\u201d would include, but would not be limited to: the deposit or withdrawal of currency by an individual at the teller window, an individual making a loan payment with currency at the teller window or, an individual exchanging currency at the teller window. The option \u201cAggregated transactions\u201d is not the same as Item 3 \u201cMultiple transactions,\u201d which can involve transactions that are above the reporting requirement.<\/em><\/p>\n

    Frequently Asked Questions Regarding the FinCen Currency Transaction Report (CTR) #27:https:\/\/www.fincen.gov\/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr<\/a><\/p>\n

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    Compliance Alliance offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call (888) 353-3933<\/strong> or email info@compliancealliance.com<\/a><\/strong> and ask for our Membership Team.\u00a0Compliance rules and regulations change quickly! For timely compliance updates, subscribe to Compliance Alliance\u2019s email newsletters<\/a><\/strong>.\u00a0Not a member? <\/strong>Learn more about membership with Compliance Alliance by attending one of our live demos:<\/p>\n