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A Large Cash Transaction Report (LCTR) is a mandatory report that certain reporting entities, including some in the mortgage sector, must file with FINTRAC whenever they receive $10,000 or more in cash in a single transaction, or in two or more related cash transactions within 24 hours.
Most mortgage funds move electronically between the lender, the lawyer, and the borrower, so brokers themselves rarely trigger an LCTR directly. But any reporting entity in the transaction — a private lender accepting a cash payment, or a brokerage or administrator that does handle large cash amounts — must file within 15 calendar days of receiving $10,000 or more in cash, and keep records of the report for five years.
The 24-hour aggregation rule exists to catch structuring: two or more cash transactions under $10,000 each, from the same client within 24 consecutive hours, that together total $10,000 or more still trigger a single LCTR. An LCTR is separate from a suspicious transaction report — it's triggered automatically by the dollar amount, not by suspicion — but a broker who notices a client pushing for a large cash payment on a private deal should still flag it to their compliance officer.
$10,000 threshold: an LCTR filing is triggered by receiving $10,000 CAD or more in cash in a single transaction.
24-hour aggregation rule: two or more cash transactions under $10,000 each, from the same client within 24 consecutive hours, that add up to $10,000 or more must also be reported as a single LCTR.
15-day filing deadline: reporting entities must submit the LCTR to FINTRAC within 15 calendar days of the transaction, and retain records for five years.
Distinct from a suspicious transaction report: link suspicious transaction report — an LCTR is triggered automatically by the cash amount, while a suspicious transaction report is filed based on reasonable grounds to suspect money laundering or terrorist financing, regardless of the amount.
Definitions reflect Canadian federal and provincial rules as of the “Updated” date above. Not advice for any specific file.
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