Tell us
what you think
Our Sponsors
 |
Our Sponsors
|
Question & Answer
Question: We just discovered we were using calendar days instead of business days to aggregate transactions to file CTRs. Now we find we have five transactions over the past year that should have been filed but weren't. What do we do about them?
Answer: File! One of our contacts at FinCEN was quoted at a Bank Secrecy Act conference as saying, "We have never yet fined a financial institution for late filing a CTR on a missed transaction they found themselves. We have fined for NOT filing, or for late filing on transactions the bank has missed but the examiners have discovered."
One Washington DC agency said you should put a cover letter on the overdue CTRs explaining that during your audit it was discovered that a 4789 was not filed for these transactions and that procedures are now in place so that it won't happen again, and if there are any questions the contact is named below, with a telephone number, etc., etc.
Another DC agency said you should just write a letter to Detroit, tell them about the missing transactions in the letter and ask them if they want you to now file.
The HOTLINE staff went with the first suggestion- but you can take your pick.
Copyright © 1996 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 6, No. 11, 9/96
Rate This Article
Current Rating For the Feature:
| Total Ratings for this Feature: 0 |
|