CBT Banking Regulations & Compliance 2 — Questions and Answers
Question 1: A customer deposits $6,000 in cash at the main branch in the morning and $5,000 in cash at another branch of the same bank that afternoon. What is the bank's CTR obligation?
- No CTR is required because each deposit is under $10,000
- A CTR is required because same-day cash transactions by the same person must be aggregated (Correct answer)
- A SAR must be filed instead of a CTR
- A CTR is required only if both deposits occurred at the same branch
Correct answer: A CTR is required because same-day cash transactions by the same person must be aggregated
Banks must aggregate multiple cash transactions by or for the same person in one business day, and $11,000 exceeds the $10,000 CTR threshold.
Question 2: Within how many calendar days after the transaction must a Currency Transaction Report be filed with FinCEN?
- 5 days
- 10 days
- 15 days (Correct answer)
- 30 days
Correct answer: 15 days
CTRs must be filed within 15 calendar days after the date of the reportable transaction.
Question 3: A customer asks a teller, "How much cash can I deposit before you have to report it to the government?" and then reduces the deposit to $9,500. What should the teller do?
- Process the deposit and take no further action since it is under $10,000
- Refuse the deposit entirely
- Process the deposit and refer the activity for possible SAR review per bank policy (Correct answer)
- Advise the customer to split the deposit across two days
Correct answer: Process the deposit and refer the activity for possible SAR review per bank policy
Adjusting a transaction to evade CTR reporting is possible structuring, which should be escalated for SAR consideration.
Question 4: Under the Bank Secrecy Act, cash purchases of cashier's checks, money orders, or traveler's checks between $3,000 and $10,000 inclusive require the bank to:
- File a CTR
- Record specific purchaser information in a monetary instrument log (Correct answer)
- Obtain manager approval and notify OFAC
- Place a hold on the instrument for 5 business days
Correct answer: Record specific purchaser information in a monetary instrument log
BSA recordkeeping rules require purchaser details to be recorded for cash purchases of monetary instruments of $3,000 to $10,000.
Question 5: Which of the following is a minimum piece of information the Customer Identification Program (CIP) requires before opening an account for an individual?
- Employer name
- Annual income
- Date of birth (Correct answer)
- Mother's maiden name
Correct answer: Date of birth
CIP requires at minimum name, date of birth, address, and an identification number for individuals.
Question 6: A teller tells a customer that the bank has filed a Suspicious Activity Report about their transactions. This action is:
- Required so the customer can respond
- Permitted if the customer asks directly
- A prohibited disclosure under federal law (Correct answer)
- Allowed only after the SAR has been accepted by FinCEN
Correct answer: A prohibited disclosure under federal law
Federal law prohibits disclosing a SAR or the fact that one was filed to the subject of the report.
Question 7: How long must a bank generally retain BSA records such as CTRs and SARs with supporting documentation?
- 1 year
- 3 years
- 5 years (Correct answer)
- 7 years
Correct answer: 5 years
BSA records, including CTRs, SARs, and supporting documentation, must be kept for five years.
