Q: Our member deposited $9,000 in cash at the credit union in the morning and later in the day withdrew $3,000 in cash from an ATM. Do we need to fill out a Currency Transaction Report (CTR)?

A: No. When aggregating cash transactions for CTR filing, the credit union must consolidate deposits (cash in) and withdrawals (cash out) separately. The credit union wouldn’t add deposits and withdrawals together, or offset them.

Bank Secrecy Act regulations require financial institutions to report on the CTRs all currency (cash or coin) transactions of more than $10,000 conducted by or on behalf of one person, as well as multiple currency transactions of more than $10,000 in a single day.

Q: How much advance notice must we provide for a change in terms under Regulation E?

A: The credit union must provide a written notice at least 21 days before the changes become effective if the change would result in increased fees or charges, increased liability for the member, fewer types of available electronic fund transfers, or stricter limits on the frequency or dollar amounts of transfers—Reg E, Section 1005.8(a).

Visit CUNA’s compliance blog— “CompBlog”—at cuna.org. Email cucomply@cuna.com with questions or ideas, and keep the conversation going with your peers on COBWEB—CUNA’s compliance listserv.

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