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Large and Shady Bank Transfers Are Reported

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Did you know that if you get a $9,999 transfer from your parents to help you out on a down payment, the bank won’t be required by the Bank Secrecy Act to report the deposit on a Currency Transaction Report (CTR); if they give you $10,000 then they are required to report it? The purpose behind these, and other reports mandated by the BSA, reports is to help the Feds find out if someone is laundering money.

Now, if there are a whole bunch of transfers for $5,000, the bank could always opt to report the transfers if they suspect something is fishy. This way they can report the deposits even if they don’t individually exceed $10,000 themselves.

The FinCEN Form 104 Currency Transaction Report (CTR) is the report that is filed when there is a transaction (deposit, withdrawal, currency conversion, etc) over $10,000 or over. The FinCEN Form 105 Report of International Transportation of Currency or Monetary Instruments (CMIR) is the report that is filed when someone transports or causes to be transported into or out of the United States.

Now, if the bank suspect something is up (i.e. a law is being broken), they’ll file a Treasury Department Form 90-22.47 and an OCC Form 8010-9, 8010-1 Suspicious Activity Report (SAR).

Whew!

So, what does this mean for the average Joe? Nothing really… it’s just a big of useful trivia. :)

{ 25 comments, please add your thoughts now! }

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25 Responses to “Large and Shady Bank Transfers Are Reported”

  1. Blaine Moore says:

    I knew that there was a reason that I haven’t closed my unused online banking accounts…heheh…

    If only there was somebody to fill them up with $9000 deposits…I don’t suppose that if they were made to different accounts that the form would get filed.

  2. JasonP says:

    Clarification, these reports are filed only when the transaction involves actual paper cash. Wire, ACH, checks, etc.. are not included.

  3. dong says:

    yeah, I learned this from watching the Sopranos.

  4. Kevin Spring says:

    I wonder if my bank did this to me when I deposited $15,000 into my account the other day. I got it from Amex for 0% credit card arbitrage.

  5. zevgoldman says:

    The reporting amount can be changed daily. Sometimes it as low as two thousand dollars. the ten thousand dollar figure is a smoke screen to more or less catch people who are repeatedly trying to stay under that figure to avoid detection.

  6. MoneyNing says:

    Hmm. I wonder if there is another rule that governs wire transfers? What if someone’s parents is paying for their daughter’s house and wanted to transfer the money to her bank account first?

  7. Tom says:

    Jason is correct, this is only for paper cash transactions. Also, its actually any cash transactions *over* $10000 meaning that you can withdraw $10k without a CTR, but if you take $10000.01 then a CTR needs to be filed.

    Also, if a teller tells you what the threshold is for filing a CTR they may be guilty of violating the Bank Secrecy Act and could be subject to some serious criminal penalties. Its illegal to structure cash transactions in order to avoid a CTR. For example, if you have $11k burning a hole in your pocket and deposit $5000 today and $6000 tomorrow, you are now a criminal.

    Sorry, I work in a bank and this is just so fascinating to me. Yes, I’m a nerd.

  8. JasonP says:

    Tom,
    Having a CTR or a SAR report filed for you doesn’t mean you’re in any type of trouble or are a criminal. Its just their way of red-flagging it for a closer look to make sure you’re legit. For example, a vending machine business owner depositing $15k in cash once a month isn’t a criminal, nothing is wrong with it. They’ll just check it more closely to make sure its not from criminal activity and isn’t being laundered.
    I used to work at a retail bank, by far the worst job I’ve ever had.

  9. Tom says:

    I’m not suggesting that. But to structure your deposits in order to avoid a CTR is a crime. And I do work at a retail bank currently. Not such a bad gig if you ask me. ;)

  10. JasonP says:

    Structuring is also not a crime, just another thing you could be written up for to be flagged (with a SAR instead of a CTR). Its not a crime to make multiple deposits instead of one big one, but it is something tellers look out for to write a SAR for. The SAR basically exists so that people making multiple deposits are written up the same way people making big deposits are. No two are a crime.

  11. Anonymous says:

    I just made a payment of $14,130.00 to my mortgage company
    by using a personal check (no cash). Is this something that they
    would report to the IRS?

  12. Anonymous says:

    Does anyone know what the IRS/FinCEN does after they receive a report?
    I just deposited a large sum of money, and am wondering if they’ll come after me at work or something with all these questions.

  13. Mo says:

    If someone deposits a larger sum of like ten million dollars from a bank transfer into their bank account, what will happen?

  14. Investor says:

    It’s sad that someone who even works at a bank truly believes that making multiple deposits under $10,000 to avoid the CTR reporting to the IRS is a crime. It’s not! And you shouldn’t be working in the banking business if you believe so. How is your customer service to people who are making multiple deposits when you are falsely accusing them of being criminals? Get smarter. Get an education. Be better informed.

  15. Tesa says:

    I have the same question! I, along with someone I lived with for years, accumlated over $10,000 in cash over the years. He died recently, and I wasn’t comfortable holding on to that much cash so I deposited it yesterday. They took copies of my credit card,ID, asked questions..now I am worried! What happens now?

    • Jim says:

      Mostly nothing, it’s just a form they have to fill out.

      • Tesa says:

        Do they file that form with a goverment agency and should I be expecting a call from that agencey?

        • Tweetygirl says:

          I also had the same thing happen to me, I deposited a large amount of cash into my bank account and my teller handed me a pamphlet and told me she would be asking me a series of questions. What happens now? Does the IRS get involved? In over a 10 year period I’ve had cash put away and decided to deposit because I didn’t feel comfortable anymore with money in my house. Now i can’t help but feel it would have been better not to make the deposit at all, The whole situation is scary exspecially when I was told Im being reported for making a large deposit.

  16. Tesa says:

    PS: I have 2 different accts..one for the house we owned together and one for the residence I’m living in now ( long story )..I split the deposit between those two accts in addition to the three different types of savings I have within each acct( checking, prefered, mint, it’s a bank thing . Now I’m seeing things on the internet about illegal “structuring”! How did making a deposit of my own money get so complicated?!

  17. LanaLove32 says:

    I got a saving account on hold that I haven’t used in 2 months,I am currently waiting for a wire transaction to hit my bank account that is somewhere over $10,000 would I need to worry about the bank reporting this wire transaction and do wire transaction bounce like money orders and checks,be reversed?

  18. Rob says:

    Can you ask a bank for a copy of any CTRs they filed? My bank says they rarely file when the customer is a regular. However, I read some bank’s computers will automatically do this.

  19. Char113 says:

    If I transfer 20k from my OWN online savings account to my OWN checking account, will this be reported? NOTE: My online savings account is a different bank than my personal checking account- thanks for any information that would be of help.

  20. Nicki says:

    This is SO lame! Why would they (the bank) have to report any large withdrawals?? I can understand large DEPOSITS, but WITHDRAWALS? how did taking your own money out of the bank become so damn confusing and complicated?? I for one, am sick of the banks and much rather hold on to some cold, hard cash instead! But now reading all this, makes me wonder how I will be able to pull my OWN money out of the bank without having to worry about some lame form being filed against me? It’s my OWN hard earned money! what do they care how I spend it or for that matter, WHERE i choose to keep it?? Guess I’ll have to do numerous, spanned out withdrawals to stay under the radar!

  21. Kurt says:

    Guys….depositing and withdrawing money from an account that you own, or have a legal right to access, is not a crime. You can deposit or withdrawl ANY amount. If you are doing legit business transactions, you have no reason to worry. Now forgetaboutit….:)


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