A client pays a $25,000 cash deposit for a property purchase. What FINTRAC obligation does this trigger for the real estate professional?

Q: What is the correct answer to: A client pays a $25,000 cash deposit for a property purchase. What FINTRAC obligation does this trigger for the real estate professional?

The correct answer is Submit a large cash transaction report within 15 days. Option B is correct because FINTRAC regulations require real estate professionals to file a Large Cash Transaction Report (LCTR) within 15 days for any cash transaction of $10,000 or more. The $25,000 deposit exceeds this threshold, automatically triggering the reporting requirement. This is mandated under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and applies to all cash transactions above the threshold, regardless of whether they appear suspicious.

Q: What background knowledge is needed for this Regulatory Compliance question?

FINTRAC is Canada's financial intelligence unit that combats money laundering and terrorist financing. Real estate professionals are designated reporting entities under federal legislation who must file Large Cash Transaction Reports (LCTRs) for cash transactions of $10,000 or more within 15 days. They must also file Suspicious Transaction Reports when they have reasonable grounds to suspect money laundering. Cash includes currency, coins, and negotiable instruments like money orders. These requirements apply across all provinces and are separate from provincial real estate regulations like TRESA, RESA, or REDMA.

Q: What is a good way to remember the answer to this Regulatory Compliance question?

Remember 'Ten-Fifteen': $10,000 threshold triggers a 15-day deadline for Large Cash Transaction Reports. Think of it like a countdown - once you hit the $10K mark, you have 15 days to report to FINTRAC, just like you have 15 days to return a library book. When you see any cash amount over $10,000 in a question, immediately think 'Ten-Fifteen' - this triggers the LCTR requirement with a 15-day deadline. Don't confuse it with suspicious transaction reporting which has different triggers.

Q: What exam tip applies to this Regulatory Compliance question?

Look for cash amounts over $10,000 - they automatically trigger LCTR filing within 15 days. Don't overthink whether the transaction seems suspicious; the reporting requirement is based solely on the dollar threshold for legitimate transactions.

Q: How does this Regulatory Compliance concept apply in real world practice?

A buyer arrives at your office with $30,000 in cash for a deposit on a condo purchase. While unusual, this is a legitimate transaction. You must accept the deposit, complete the required client identification, and file a Large Cash Transaction Report with FINTRAC within 15 days. You would document the transaction details, verify the client's identity, and submit the report online through FINTRAC's portal, ensuring compliance with federal anti-money laundering requirements.

Question

Regulatory ComplianceFINTRAC Anti Money LaunderingMEDIUM

A client pays a $25,000 cash deposit for a property purchase. What FINTRAC obligation does this trigger for the real estate professional?

Answer Options

A

File a suspicious transaction report within 24 hours

B

Submit a large cash transaction report within 15 days

C

Conduct enhanced due diligence on the client

D

Refuse the cash payment and require certified funds