August 29, 2012 - 1:35pm
#1
Scenario - a member makes a large cash deposit into his personal account. On the same date, at another branch, a large cash deposit is made into a business account on which the previously mentioned member is one of two signers. Both transactions total more than $10,000. Is a CTR required?
Risk Management believes not because can not confirm which business owner made the deposit. However, the one member benefits from both accounts.
