VIDEO: The Multiple Transactions Box on a CTR
In this Compliance Clip (video), Adam answers a question on when to check the “Multiple transactions” box on a CTR. The answer has three different parts and watch out for the the little nugget of compliance love, as he likes to call it, at the end. This is a BSA/AML topic.
Video Transcript
The following is a transcript of this video:
This Compliance Clip is going to discuss the multiple transactions box on the CTR. This is a BSA/AML topic. The question we have today is this: When do you check the “multiple transactions” box, which is Item 3 on a CTR?
The answer to this could come from the CTR instructions but today we're going to take a little bit of a deeper dive and answer this from CTR Frequently Asked Question number 18. This answer has three different parts we're going to talk about. So there's quite a bit of information here. There is a little nugget of compliance love at the end that we definitely want to discuss that some of us may have overlooked based on how our organization does some things. So let's take a look.
Frequently Asked Question number 18 says this, “CTR filers should check “Multiple transactions”, which is Item 3, if there were multiple cash-in or cash-out transactions of any amount conducted in a single business day by or for the person recorded in Part I. “Multiple transactions” is not the same as item 24, which is aggregated transactions, which only involves multiple transactions, all of which are below the reporting requirements and requires at least one of the transactions to be a teller transaction.” If you want to know more information on that, you would take a look at Frequently Asked Question number 27 because that's discussed more in detail there.
Moving on in Frequently Asked Question number 18, it gives us an example. It says, “For example, if Tom Doe deposited $6,000 to his personal account in the morning and then later in the same business day deposited an additional $5,000 to his personal account, the filing institution would check Item 3 “Multiple transactions” when completing Part I on Tom Doe. Another example would be if Tom Doe deposited $7,000 into ABC restaurant's business account and then later in the same business day, Jane Smith deposited $5,000 in the ABC restaurant’s business account, the filing institution would check Item 3 ”Multiple transactions” when completing a Part I on ABC restaurant.” That's what of course, because all those transactions were done for the benefit of ABC restaurant. Now they do note here, “however, the filing institution is not going to check Item 3 “Multiple transactions” when completing a Part I on either Tom Doe or Jane Smith” because neither of them had multiple transactions. The multiple transactions only related to ABC restaurant, therefore you would only have the multiple transactions box checked for that case.
That's all pretty straightforward, but the little nugget of compliance love that I wanted to point out is the very end of this frequently asked question. What it says is this, “There may be instances where at one time an individual brings in funds to deposit to multiple accounts at the financial institution.” So they're bringing in multiple deposits at the same time. So what do you do? Well, the frequently asked question says “Whether or not to check multiple transactions in these instances depends on the financial institution’s procedures. For example, if a customer brings in $15,000 and deposits the funds to three different accounts; the financial institution posts each transaction individually, choosing, as a matter of policy, to define each as a separate transaction.” So based on their policy, they posted each individually as a separate transaction. That's how the financial institution does it even though the customer brought it in all at once. In this case, when you're completing a Part I on the conductor, the financial institution would check Item 3 “Multiple transactions” as a result of its procedures to post the transactions individually and treat each one as a separate transaction. How you treat this specific situation is going to depend on your specific procedures. If you've always done it one way, you may have never known of this little compliance nugget of love as I like to call it.
Hopefully you learned something today. That's all I have for this Compliance Clip.