Bank called my business manager

[Pepper11]

So I just opened a new bank account. I deposited a check from my investment group. My business manager informed me that someone had called her to inquire if I was a member of the investment group listed on my check. It turned out to be the bank trying in an attempt to 'approve' my check. Is this standard practice? I have never heard of such a thing in my encounters with precious banks. I called them to express extreme dissatisfaction and they claim it's for my protection. Seems very sketchy to me that they are going to have to call to approve all my checks. Wondering if I should bail on these guys asap.

[Cyclone]

You just opened a new account. Don't you want the bank to make sure that someone isn't stealing from you?

[cheese_breath]

So I just opened a new bank account. I deposited a check from my investment group. My business manager informed me that someone had called her to inquire if I was a member of the investment group listed on my check. It turned out to be the bank trying in an attempt to 'approve' my check. Is this standard practice? I have never heard of such a thing in my encounters with precious banks. I called them to express extreme dissatisfaction and they claim it's for my protection. Seems very sketchy to me that they are going to have to call to approve all my checks. Wondering if I should bail on these guys asap.

Did they say this, or are you assuming it?

[Pepper11]

That was an assumption after speaking with them. They said they will not have to do it will all checks, which presumably means they will have to do it with some.

Maybe this is standard practice, but I have been with multiple banks and have deposited a lot of 'first' checks, and have never gotten any calls like this before.

[Pu239]

So I just opened a new bank account. I deposited a check from my investment group. My business manager informed me that someone had called her to inquire if I was a member of the investment group listed on my check. It turned out to be the bank trying in an attempt to 'approve' my check. Is this standard practice? I have never heard of such a thing in my encounters with precious banks. I called them to express extreme dissatisfaction and they claim it's for my protection. Seems very sketchy to me that they are going to have to call to approve all my checks. Wondering if I should bail on these guys asap.

I just opened a new checking account in person and the bank said I couldn't withdraw any of the first deposit for the first month. Bank of the West. I'm sure they would also tell me it's "for your protection". I already have an unfavorable impression of this bank.

[ResearchMed]

So I just opened a new bank account. I deposited a check from my investment group. My business manager informed me that someone had called her to inquire if I was a member of the investment group listed on my check. It turned out to be the bank trying in an attempt to 'approve' my check. Is this standard practice? I have never heard of such a thing in my encounters with precious banks. I called them to express extreme dissatisfaction and they claim it's for my protection. Seems very sketchy to me that they are going to have to call to approve all my checks. Wondering if I should bail on these guys asap.

I just opened a new checking account in person and the bank said I couldn't withdraw any of the first deposit for the first month. Bank of the West. I'm sure they would also tell me it's "for your protection". I already have an unfavorable impression of this bank.

Would that be the case if you had deposited some cash, so the bank didn't need to worry about any new fraudulent account (with fraudulent deposits)?

RM

[Pu239]

Would that be the case if you had deposited some cash, so the bank didn't need to worry about any new fraudulent account (with fraudulent deposits)?

RM

No, they specifically said cash would not have that restriction. But who these days walks around with a pocket full of cash intending to open an account? A hold of a few days or maybe 10 might be expected but 30 days? First time I've ever run into this restriction.

[whodidntante]

Checks are pretty weird because it isn't 1930 and we have computers now. Similarly I am e-communicating with you right now instead of writing you a letter. Try using electronic deposits and transfers and see if the bank thinks those are weird.

[NYGiantsFan]

Checks are pretty weird because it isn't 1930 and we have computers now. Similarly I am e-communicating with you right now instead of writing you a letter. Try using electronic deposits and transfers and see if the bank thinks those are weird.

I have done ACHs with a big bank(I have been client for 10+ years) and they thought ACH was weird. They performed background check on me over the phone and asked lots of questions regarding ACHs.

[sport]

Unless there was some major inconvenience involved, I would close that account, tell them why, and go to another bank. For the bank to discuss your private business with a third party is unforgivable.

[123]

It was not necessarily a negative situation. Perhaps the bank called to verify the check to grant you immediate "good funds" as a courtesy. Was the check drawn on the same bank as you opened the account at? What was the face value amount of the check? Lots of good reasons for a bank to go the extra mile and call about a check. It should likely happen more often. Perhaps the bank had a knowledge of past issues with checks from the Investment Group. Were you the signer on the check from the Investment Group? Was the check presented a standard offset-printed stock bank check or was it generated entirely by computer software? There can be a lot of issues.

[Sidney]

Banks are increasingly under scrutiny regarding money laundering. This is normal.

[KandT]

My bigger question is why is the bank telling your business manager your personal information?? I would hope your doctor doesn't call and ask her if you've been exercising regularly.

[Lee_WSP]

It is only standard if the bank has some reason to expect that the check may have been forged/fraudulent. Or if it is an internal policy of that particular bank (in which case, that seems like a lot of manpower wasted on check checking, but I'm not a bank manager).

[cherijoh]

Would that be the case if you had deposited some cash, so the bank didn't need to worry about any new fraudulent account (with fraudulent deposits)?

RM

No, they specifically said cash would not have that restriction. But who these days walks around with a pocket full of cash intending to open an account? A hold of a few days or maybe 10 might be expected but 30 days? First time I've ever run into this restriction.

The solution would have been to get a cashier's check from the other bank, which you could have deposited at the new bank without any issue.

A 30 day hold does seem excessive. Check holds are usually based on the amount of the deposit (bigger deposit means longer hold) and the length of your relationship (brand new account holders get the longest hold period). For a check of say several thousand dollars and a new customer a hold of 10 days is about what I would expect.

[KandT]

I had a bank ask what I was using a check for. I asked why the teller needed to know what I was buying?? She said it was for my protection. I said I figured out how to get $62K free and clear, I could probably handle this transaction as well. Then all the sudden she didn't need to know.

Mind you she didn't need to fill out a report. When I brought in a check for a similar amount they said there was no way to tell if it was a good check until it cleared. I said can't you call the bank and make sure it is good (it was a cashiers check but I wanted to make sure it wasn't forged). "Oh yeah I guess we could do that." Seemed my protection wasn't worth a phone call that day.

[sport]

I had a bank ask what I was using a check for. I asked why the teller needed to know what I was buying??

When my mother was in a nursing home, I had POA for her bank accounts. When I cashed out a matured CD, the teller had the nerve to ask what I was going to do with the money. I gave her an icy stare and said I was using it to meet my mother's needs. Then the teller apologized.

[ResearchMed]

But why is the bank calling your "business manager"?
How do they even know that you have one, or who it is?
And why are they discussing your account with someone else?

RM

[Lee_WSP]

Would that be the case if you had deposited some cash, so the bank didn't need to worry about any new fraudulent account (with fraudulent deposits)?

RM

No, they specifically said cash would not have that restriction. But who these days walks around with a pocket full of cash intending to open an account? A hold of a few days or maybe 10 might be expected but 30 days? First time I've ever run into this restriction.

The solution would have been to get a cashier's check from the other bank, which you could have deposited at the new bank without any issue.

A 30 day hold does seem excessive. Check holds are usually based on the amount of the deposit (bigger deposit means longer hold) and the length of your relationship (brand new account holders get the longest hold period). For a check of say several thousand dollars and a new customer a hold of 10 days is about what I would expect.

I also agree that a hold of 30 days on a check sounds excessive. However, PU239 is the first post mentioning 30 days, so I'm not sure where the 30 days is coming from.

[Silk McCue]

I also agree that a hold of 30 days on a check sounds excessive. However, PU239 is the first post mentioning 30 days, so I'm not sure where the 30 days is coming from.

The 5th post in this thread was authored by PU239 and they referenced a personal experience with a “month” hold. That morphed later to 30 days.

Cheers

[khh]

I paid $5,300 with a personal check for central air installation a couple of weeks ago. The guy took a picture of the check with his phone, wrote "Mobile Deposit" on it, then handed it back. When I went online a few minutes later, the funds had already been withdrawn from my bank account.

[arcticpineapplecorp.]

it's called "Know your customer". Especially when you're new to a bank or other financial institution, they've got to get to know you:

https://www.google.com/search?client=fi ... r+customer

it is for your safety, but also for the bank's.

[celia]

So I just opened a new bank account. I deposited a check from my investment group. My business manager informed me that someone had called ...

I wonder why they didn’t call the investment group instead to confirm the check was good? What does your business manager have to do with this?

That said, I once worked for a small (15 people) start-up company. One day, the president went to the bank to cash a check written out by the company for a large amount. The bank called the employee bookkeeper to confirm the check was ok to cash. After approving it, the bookkeeper starting laughing and we all found out what happened, and laughed about it too.

[fru-gal]

I had a bank ask what I was using a check for. I asked why the teller needed to know what I was buying?? She said it was for my protection. I said I figured out how to get $62K free and clear, I could probably handle this transaction as well. Then all the sudden she didn't need to know.

When I close out a large CD at one of my credit unions, I am almost always asked what I am doing it for. I am no spring chicken, and I figure they want to be sure I'm not sending it to Nigeria.

[celia]

I had a bank ask what I was using a check for. I asked why the teller needed to know what I was buying?? She said it was for my protection. I said I figured out how to get $62K free and clear, I could probably handle this transaction as well. Then all the sudden she didn't need to know.

When I close out a large CD at one of my credit unions, I am almost always asked what I am doing it for. I am no spring chicken, and I figure they want to be sure I'm not sending it to Nigeria.

But what if you WANT TO send it to someone in Nigeria?

I guess there’s a fine line between being alert for elder abuse and client privacy.

[michaeljc70]

I'm confused. Who was the check made out to and what name is on the account? How do they know who your business manager is?

As to the other post about a 30 day hold, that is not allowed. 9 business days is the longest they can hold a check on a new account legally.

[Bacchus01]

You just opened a new account. Don't you want the bank to make sure that someone isn't stealing from you?

Wouldn’t the bank want to call YOU in that scenario?

[BSBHead]

I suspect this is due to two separate issues. The check hold is confirm your employer checked clears. I'm sure they gave you the standard hold language as check clearing can vary. A check from a large national bank deposited into your large national bank account will clear quickly as the depositing bank will image and present the check electronically. Smaller banks would likely take more time on either side.

The question about funds has to do with money laundering. FinCen and some of the other regulators have stepped up enforcement on money laundering. Banks need to know the origin and use of funds for all customers to have reasonable confidence the funds are legitimate. Opening an account is always a point of greater risk as a fraudster could be using the initial deposit as a way to clean terrorist funds or other illegal monies. FinCen really stepped up enforcement in this area starting two years ago. It's a bitter pill to swallow on the privacy front, but FinCen in their enforcement memos has stated that privacy does not override the money laundering concerns. Unfortunately, retail bank employees aren't trained to be lawyers and cannot explain this clearly to customers. I don't know if banks flag customers who flag customers who get mad or close accounts citing privacy, but I think it's possible as clearly that's exactly the kind of behavior a fraudster would exhibit if confronted by a bank employee.

[ResearchMed]

You just opened a new account. Don't you want the bank to make sure that someone isn't stealing from you?

Wouldn’t the bank want to call YOU in that scenario?

Right.

And how is someone stealing from "you" when "you" are *depositing* someone else's check?

And shouldn't they hold the check and contact the person who wrote the check, not the payee's associate anyway?



RM

[Cyclone]

My answer was based on my (probably incorrect) understanding of the original post. I thought the "OP" was depositing a check from one of his other accounts. I was thinking that it would be possible for someone to have stolen his checkbook and posing as him to open a new account.

I have worked in banks for over 30 years now. Yes, we all have less privacy now. Bankers should be trained to ask where money from your account is going to and coming from. Elder abuse is especially a big concern (even if you don't consider yourself "elder"). Answering their questions with an icy stare or "None of your damn business!" could lead to the bank closing your account. That's just the way it is now.

[michaeljc70]

I suspect this is due to two separate issues. The check hold is confirm your employer checked clears. I'm sure they gave you the standard hold language as check clearing can vary. A check from a large national bank deposited into your large national bank account will clear quickly as the depositing bank will image and present the check electronically. Smaller banks would likely take more time on either side.

The question about funds has to do with money laundering. FinCen and some of the other regulators have stepped up enforcement on money laundering. Banks need to know the origin and use of funds for all customers to have reasonable confidence the funds are legitimate. Opening an account is always a point of greater risk as a fraudster could be using the initial deposit as a way to clean terrorist funds or other illegal monies. FinCen really stepped up enforcement in this area starting two years ago. It's a bitter pill to swallow on the privacy front, but FinCen in their enforcement memos has stated that privacy does not override the money laundering concerns. Unfortunately, retail bank employees aren't trained to be lawyers and cannot explain this clearly to customers. I don't know if banks flag customers who flag customers who get mad or close accounts citing privacy, but I think it's possible as clearly that's exactly the kind of behavior a fraudster would exhibit if confronted by a bank employee.

This is completely impractical. I've worked at several banks, including the largest in the country. Banks that have millions of customer and tens of millions of deposits and cannot know the source of all such funds. Of course, banks need to be on the lookout for suspicious activity, comply with FATCA, anti-terrorism laws, etc. For example, I go in and try to deposit $15k in cash. The teller tells me they need to fill out forms and report it. I leave with the money. The next two days I deposit $7500 in separate transactions. They need to be on the lookout for things like that. I have never had a bank ask me where a check came from I am depositing. That includes large amounts from sales of property, closing of brokerage accounts, etc.

[Cyclone]

Oh, another reason they may be asking. Let's say you sold an investment property and you are depositing a large check. You might be a potential customer for some of their non-deposit investment products. The teller might get $50 if you buy one of their wonderful annuities.

[Pu239]

No, they specifically said cash would not have that restriction. But who these days walks around with a pocket full of cash intending to open an account? A hold of a few days or maybe 10 might be expected but 30 days? First time I've ever run into this restriction.

The solution would have been to get a cashier's check from the other bank, which you could have deposited at the new bank without any issue.

A 30 day hold does seem excessive. Check holds are usually based on the amount of the deposit (bigger deposit means longer hold) and the length of your relationship (brand new account holders get the longest hold period). For a check of say several thousand dollars and a new customer a hold of 10 days is about what I would expect.
[/quote]

It was just a few hundred dollars written on an account from a local bank. The hold is not a problem but seems excessive given the efficiency of banking systems these days. I've had checks of tens of thousands of dollars held for less time.

[Pu239]

Checks are pretty weird because it isn't 1930 and we have computers now. Similarly I am e-communicating with you right now instead of writing you a letter. Try using electronic deposits and transfers and see if the bank thinks those are weird.

Yes, but I still live in the 20th century. Want to see my new flip phone?

[cherijoh]

No, they specifically said cash would not have that restriction. But who these days walks around with a pocket full of cash intending to open an account? A hold of a few days or maybe 10 might be expected but 30 days? First time I've ever run into this restriction.

The solution would have been to get a cashier's check from the other bank, which you could have deposited at the new bank without any issue.

A 30 day hold does seem excessive. Check holds are usually based on the amount of the deposit (bigger deposit means longer hold) and the length of your relationship (brand new account holders get the longest hold period). For a check of say several thousand dollars and a new customer a hold of 10 days is about what I would expect.

It was just a few hundred dollars written on an account from a local bank. The hold is not a problem but seems excessive given the efficiency of banking systems these days. I've had checks of tens of thousands of dollars held for less time.

In that case, I would rethink why I was setting up an account at this bank. At some point an excessive hold might prevent you from getting access to your money when you needed it.

[feehater]

The solution would have been to get a cashier's check from the other bank, which you could have deposited at the new bank without any issue.

I'm not sure this is always true either? When I went to grad school in a different part of the country I switched banks to one that existed both at home and where I was moving to. I withdrew my entire live savings (maybe $8- 10k) from the old bank with a cashier's check and walked across the street and deposited it in the new bank. (This was just before the days of easy online linking and ACH transfers). Before they would deposit it they asked me where I'd gotten the check from and called the branch of the other bank to confirm it. To be fair, I was a poorly dressed 21 year old and for some reason I'd chosen to do it halfway through my trip, so I was in a city I didn't live near.

[inbox788]

My bigger question is why is the bank telling your business manager your personal information?? I would hope your doctor doesn't call and ask her if you've been exercising regularly.

I'm confused about what personal information was compromised. When a person writes a check to another, the banks involved need some information to transfer the funds from one persons account to another. Was the check a large (> $10k, reportable) or an unusually large amount?

So I just opened a new bank account. I deposited a check from my investment group. My business manager informed me that someone had called her to inquire if I was a member of the investment group listed on my check. It turned out to be the bank trying in an attempt to 'approve' my check. Is this standard practice? I have never heard of such a thing in my encounters with precious banks. I called them to express extreme dissatisfaction and they claim it's for my protection. Seems very sketchy to me that they are going to have to call to approve all my checks. Wondering if I should bail on these guys asap.

Can you clarify the actors? It's unclear why they had to make a phone call, and what information they were seeking or conveying other than what was necessary to confirm identities of the parties involved in the transaction.

What is "my investment group"? Are there multiple signers on the account? Did you sign the check to yourself? How is the business manager related to the "investment group listed on my check"? Does the business manager have access to "investment group" account? And did the bank disclose anything that wouldn't be available to the account holders?

If this was a "big corp" check instead, would things be the same or different? Why?

[KandT]

My bigger question is why is the bank telling your business manager your personal information?? I would hope your doctor doesn't call and ask her if you've been exercising regularly.

I'm confused about what personal information was compromised. When a person writes a check to another, the banks involved need some information to transfer the funds from one persons account to another. Was the check a large (> $10k, reportable) or an unusually large amount?

Why is it the business manager's business if he is in an investment club? Many bogleheads are anonymous to many people. I personally don't discuss money with non-bogleheads because it's none of my business how much cc debt they are in even though they bought a new Mustang.

It is simply not the bank's decision who to tell he is in an investment club anymore than it is their decision to ask if he just bought a new XXX. Maybe he doesn't want the bank advertising his personal time.

[HomeStretch]

I had a bank ask what I was using a check for. I asked why the teller needed to know what I was buying?? She said it was for my protection. I said I figured out how to get $62K free and clear, I could probably handle this transaction as well. Then all the sudden she didn't need to know.

When I close out a large CD at one of my credit unions, I am almost always asked what I am doing it for. I am no spring chicken, and I figure they want to be sure I'm not sending it to Nigeria.

But what if you WANT TO send it to someone in Nigeria?

I guess there’s a fine line between being alert for elder abuse and client privacy.

Reading your responses made me laugh as I just ran into this yesterday when I closed a bank CD. Spouse’s standard answer is “I am putting it all on red”.

I find this a predatory practice at some banks. The tellers at our bank get a bonus if they “sell” you a CD or steer you to the investments desk. My parents and in-laws were steered by “helpful” tellers at other banks right into some high fee products.

[inbox788]

My bigger question is why is the bank telling your business manager your personal information?? I would hope your doctor doesn't call and ask her if you've been exercising regularly.

I'm confused about what personal information was compromised. When a person writes a check to another, the banks involved need some information to transfer the funds from one persons account to another. Was the check a large (> $10k, reportable) or an unusually large amount?

Why is it the business manager's business if he is in an investment club? Many bogleheads are anonymous to many people. I personally don't discuss money with non-bogleheads because it's none of my business how much cc debt they are in even though they bought a new Mustang.

It is simply not the bank's decision who to tell he is in an investment club anymore than it is their decision to ask if he just bought a new XXX. Maybe he doesn't want the bank advertising his personal time.

Because the business manager manages the investment club and signed the check?

If Boeing CFO wrote a check to Joe Engineer employee, would be appropriate for the banks to ask about $1M being deposited in Joe's account whether Joe worked for Boeing? I don't know, but the answer may be depends.

OP, who's name is on the check? You? Business manager? Both? Others? And who signed it? And is it a single signature or multiple? What controls does the investment club have to prevent one person from draining the account and escaping to Brazil or Ecuador?

[J295]

Lots of fencing with windmills going on here… I was a partner in a professional business .... if a bank called and had a question for me and I wasn’t available it likely gets transferred to someone else on the team, and if it’s my primary assistant or office manager etc. then they get asked a question and they answer the question if the know answer. Seems reasonably efficient, and they’re not asking for the nuclear launch codes. Relax

[inbox788]

Lots of fencing with windmills going on here… I was a partner in a professional business .... if a bank called and had a question for me and I wasn’t available it likely gets transferred to someone else on the team, and if it’s my primary assistant or office manager etc. then they get asked a question and they answer the question if the know answer. Seems reasonably efficient, and they’re not asking for the nuclear launch codes. Relax

I'm guessing the bank employee was simply trying to fill out the IRS/FinCEN Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business:

https://www.irs.gov/businesses/small-bu ... ence-guide

https://www.irs.gov/pub/irs-pdf/f8300.pdf

Was any question not something required on the form? If so, maybe the employee was inappropriate, but this type of information is being collected and reported all the time.

[ResearchMed]

OP is refusing to answer question(s) *critical* to our making informed suggestions/etc.

What is the relationship, as asked above many times, among the "investment group", the business manager, and OP.

Ordinarily, no one would call the Payee or anyone associated with the Payee to ask, in effect, "You know that money you just got? Should it really be yours?"

Nope, call the PAYOR or proxy: "Did you indeed give this check to X?"/etc.

RM

[TropikThunder]

Lots of fencing with windmills going on here… I was a partner in a professional business .... if a bank called and had a question for me and I wasn’t available it likely gets transferred to someone else on the team, and if it’s my primary assistant or office manager etc. then they get asked a question and they answer the question if the know answer. Seems reasonably efficient, and they’re not asking for the nuclear launch codes. Relax

Yes, the conspiracy theory is strong in this thread. The OP was unfortunately vague, but the simplest explanation is that it’s the business manger of the investment club, and is listed in the check. I mean seriously, how else do people think the bank knew who to call?

[ResearchMed]

Lots of fencing with windmills going on here… I was a partner in a professional business .... if a bank called and had a question for me and I wasn’t available it likely gets transferred to someone else on the team, and if it’s my primary assistant or office manager etc. then they get asked a question and they answer the question if the know answer. Seems reasonably efficient, and they’re not asking for the nuclear launch codes. Relax

Yes, the conspiracy theory is strong in this thread. The OP was unfortunately vague, but the simplest explanation is that it’s the business manger of the investment club, and is listed in the check. I mean seriously, how else do people think the bank knew who to call?

Then WHY will OP not make the simple effort of telling us that?

RM

[8foot7]

Lots of fencing with windmills going on here… I was a partner in a professional business .... if a bank called and had a question for me and I wasn’t available it likely gets transferred to someone else on the team, and if it’s my primary assistant or office manager etc. then they get asked a question and they answer the question if the know answer. Seems reasonably efficient, and they’re not asking for the nuclear launch codes. Relax

I'm guessing the bank employee was simply trying to fill out the IRS/FinCEN Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business:

https://www.irs.gov/businesses/small-bu ... ence-guide

https://www.irs.gov/pub/irs-pdf/f8300.pdf

Was any question not something required on the form? If so, maybe the employee was inappropriate, but this type of information is being collected and reported all the time.

Obviously not, since it was a check.

[Lee_WSP]

It really seems like the explanation is as simple as:

Bank had a new account opened with a check written by 3rd party
Bank called phone number on check to authenticate it
OP is upset that he/she was singled out

Why they did it is up for debate, but they certainly are allowed to do so. They can't do that for every check as it would be cost prohibitive.

[inbox788]

Obviously not, since it was a check.

I'm not a lawyer or a teller or a banker, but I believe the transaction is reportable. Like many IRS instructions, clear as mud.

[Lee_WSP]

Obviously not, since it was a check.

I'm not a lawyer or a teller or a banker, but I believe the transaction is reportable. Like many IRS instructions, clear as mud.

Not really, it says in the title "cash payments over $10,000". It's the structuring laws that are less clear, but still pretty clear. Structuring being breaking up a wad of cash greater than $10,000 to avoid said reporting form.

[TropikThunder]

Obviously not, since it was a check.

I'm not a lawyer or a teller or a banker, but I believe the transaction is reportable. Like many IRS instructions, clear as mud.

There are two different reporting mechanisms involved.
- 1. A Currency Transaction Report (CTR) is what most people think of when talking about how a bank monitors activity, and is triggered by a cash transaction: "U.S. financial institutions are required to file with FinCEN for each deposit, withdrawal, exchange of currency, or other payment or transfer, by, through, or to the financial institution which involves a transaction in currency of more than $10,000." CTR's are automatically created whenever a cash transaction $10,000 or more takes place.
https://en.wikipedia.org/wiki/Currency_ ... ion_report

- 2. A CTR by itself is not suspicious, but if a bank employee "believes the transaction to be suspicious or fraudulent" then they can also file a Suspicious Activity Report (SAR). But the use of SAR/s is much broader than for cash-only transactions: "any financial transaction that does not make sense to the financial institution; is unusual for that particular client; or appears to be done only for the purpose of hiding or obfuscating another, separate transaction." This can include "a deposit; a withdrawal; a transfer between accounts; an exchange of currency; an extension of credit; a purchase or sale of any stock, bond, certificate of deposit, or other monetary instrument or investment security; or any other payment, transfer, or delivery by, through, or to a bank." So an SAR requires a person to become suspicious and initiate the report.
https://www.ffiec.gov/bsa_aml_infobase/ ... lm_015.htm

So, a CTR does not always become an SAR, and an SAR doesn't have to involve cash.