Untangling CTRs

Last week, I had the pleasure of presenting at NAFCU’s Regulatory Compliance and BSA Seminar. My presentation was different than the normal lecture style of presentations at NAFCU Conferences. Instead, I essentially conducted a workshop for the attendees in the BSA track of Seminar. My workshop was all about Currency Transaction Reports (CTRs). We had very informative conversations so I figured I would provide some scenarios here that came up during the workshop.

First, let’s start with some background. FinCEN requires a credit union to file a CTR for each currency transaction of more than $10,000 by, through, or to the credit union. FinCEN defines currency as coin and paper money, i.e., cash.

Now we’ll get into some scenarios:

Scenario #1

Member A’s car gets repossessed, and the amount owed is $13,000; Member B purchases the car from the credit union with $13,000 cash. Should a CTR be filed against both Member A and Member B?


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