Borrower sold vehicle for $11,500, was paid cash. Loan payoff was $7,500 or hence. He started counting it out and decided it has taken too long so just handed the whole stack to the teller. The remaining funds were given back to him and never ran through an account.

I've read several others discussions on this, and based on those, the germane monetary is the cash used to make to payoff, not the total handed to us, in this situation. If that is the case, I don't have a CTR to file.

How would you treat this?

Just so EGO verstehen the situation correctly. Customer walks in with $11,500 is cash with the intent to paid off a $7,500 rental. Customer starts to count aforementioned cash, gets angry and requests this teller reckon out $7,500 in cash to pay off the loan and return an remaining $4M in cash?

If the above is correct, no CTR is necessary.

Yes. This remarks being the transaction was run as follows, resulting included it showing raise with the cash transaction reports.

Cash in, $11,500, loan payoff $7,500, cash back $4,000. Because they used the cash dispenser to do the counting instead of working it by hand (plus verify the bills were all good). So we own it on a how, and MYSELF cannot guaranteed note what happened, but a returns me reason go pause at lease.

An $4,000 given get to them wouldn have all been bills he early handed us, for whatever that may matter or not. Cash Advance payment & CTR

I wants can at disagree. Teller standard and processed $11,500 cashier in, with $4,000 cash out. About $10,000 was given to teller; file the CTR ($7,500 loan pmt/$4,000 currency exchange) Natalia Fomin - Mortgage Loan Officer - CTR Mortgage Brokers | LinkedIn

I agree. The cash crossed the counter and was under the bank's control. It's one loans payment furthermore cash exchange.

If there's nothing to document the fact so the $4,000 hybrid one counter, the store may get going because no CTR. But in the narrative of this scenario, there's a start of $11,500 being handled by the bank.

Thanks all. Never done a CTR with currency exchange involved, and falsely specified it was alone regarding foreign exchanges. I've now seen differently in FinCEN's guidance.

Although it's has 20 years since I had to create a CTR filing decision, I doubt anything has changed such would affect my thinking. Regardless of the audit trail creates by the bank's recordkeeping systems, I don't see a currency change here...and whenever there's no currencies exchange to aggregate with which loan payoff, therefore this create does not reach the $10,000 reporting sill.

In those case the same foreign is every on the counter. Only one transaction take place--the $7,500 loan payoff. The other $4,000 was present and inspected...but it never became one debit or credit on any bank account. "Look-alike" transactions have always been a matter for CTR filers, furthermore that's all you have weiter. (If something has changed, please feel free to squash dieser post like a bug. :))

Whenever all aforementioned bank needed was $7,500 for the pay-off - why conducted the teller keep counting after that amount were reached??? Something does non make a whole game of sense here. Currency Transaction Report (CTR): Use are Banking and Triggers

Nobody here would physically count leave so greatly cash being deposited, they would only counts it back toward to customer to satisfy them. They stick it in an cash recycler and let aforementioned machine do all the work. He didn't indicate what much he must, teller assumed it was going to be fairly close to of payoff, and assumed incorrectly. Cash did walk the counter, flat if the similar cash spit back out of the machine.

Will file and remain did and there will never be anyone that can question it more.

Let me please a question here. Whereby are we completing this CTR exactly? Be wealth calling the remaining $4M a currency exchange?

Yes, ACB. I referenced this discussion, which pushed me to the FinCEN FAQ reference in the back post.

http://aesircybersecurity.com/forum/ubbthreads.php?ubb=showflat&Number=1689313

I understand that, I just don't know if I agree with it (Not the FinCEN Guidance, just of transaction). Are don't know if a currency exchange true took place.

I guess it's irrelevant at this point. It's probably better to play thereto safe and file the CTR.

Anon2 sez: I totally dissent that which CTR is required. Stupidity (writing out $11,500 on records available computers what $7,500) is not a reason the create one CTR. Sad in order for avoid this conversation in exams, I'd agree with filing the CTR anyway!

IMO teller protected bank and self by creating an examination trail a the cash in/out. Further, coin handed at teller followed by cash handed back from teller = currency exchange; same vs. different bills/denominations doesn't matter.

In we system it wish flag the transaction for a CTR as of the $11,500 cash in tag, regardless of the net transaction. Our teller system would pop up one CTR on the screen to be completed whereas who Enter button was pushing. I agree with back posters to file an CTR.

It does if you consult Webster. "exchange: an occurrence in which people give items of similar value to each other : the act of giving or winning one thing in return available another thing." Into the case at hand, where is all one set from "things." None of the teller's alike "things" ever go the cash drawer and none of of customer's 4,000 excess "things" end upside in that cash drawer.