Compliance Question of the Week

For this week’s Compliance Question of the Week, we present four interrelated CTR questions.

If the husband and wife are joint on an account, and the husband deposits $11,000 in cash to the account, do I include the wife on the CTR?

Yes, as a joint owner on the account, she would be considered benefiting from the transaction.

If a husband and wife are joint on an account and each come in separately and deposit $6,000 cash on the same day, do I need to file a CTR?

Yes, this is both a multiple persons and multiple transactions CTR.  Since both husband and wife are joint on the account, they would benefit from any deposits into the account and multiple cash deposits are aggregated together.

If a husband and wife have a joint account and the husband and wife each take out $6,000 in cash on the same day, is a CTR required?

CTR’s are required if the credit union processes currency transactions greater than $10,000 that was performed by, of, or for the benefit of one person.  In this case a CTR may not be required unless you know the husband or wife is making the withdrawal for the other.  It is also possible they are attempting to structure the transaction to avoid the reporting requirements.  If this is a pattern of behavior and not a 1 time occurrence then a SAR is advisable.

If the husband makes a deposit of $4,000 cash to his individual account, and later in the same day his wife makes a $6,500 cash deposit to their joint account, do we file a CTR?

Yes.  The transactions must be aggregated if they are by or on behalf of the same person and the credit union has knowledge of them. Deposits to joint accounts are considered to be on behalf of all the owners of the account.  In this case it would be both a multiple person and multiple transactions CTR.

Related Links
1995 Treasury Guidance – Question 14

 

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted in Compliance.