Q: Is a CTR required when a person presents a check, in excess of $10,000, for payment in cash at a financial institution and receives less than $10,000 after fees, or other deductions, are charged against the amount of the check?
A: The BSA only requires a CTR for a transaction in currency, such as a deposit, withdrawal, exchange or transfer of currency, in excess of $10,000. A transaction in currency involves the physical transfer of currency from one person to another. Accordingly, the transfer of currency below $10,000 would not trigger the CTR requirement, despite the amount of the check. For example, if a person cashed a check for $10,100 and received $9,990 after a service fee was charged against the amount of the check, the financial institution would not be required to file a CTR. On the other hand, if a person purchased a cashiers check for $9,990 and paid a service fee of $20 for a total of $10,010 in cash, the financial institution would be required to file a CTR. The key lies in the amount of the physical deposit, withdrawal, exchange or transfer of currency. (10/2001)
This FAQ was obtained from FinCEN’s website, in the section for Answers to Frequently Asked BSA Questions, which may be found here: