In your institution, what is the role of BSA personnel vs. branch personnel in regards to the completion of CTRs? For instance, if a CTR is filled out incorrectly at the branch level, does the BSA Analyst handling the CTR always go back to the branch-level employee and make them correct errors? Or, does the BSA Analyst – whenever they can – correct the errors themselves without contacting the branch?

My institution is exploring ways to increase CTR-filing efficiency. Currently, everytime there's an error on a CTR, we contact the branch and have them re-fill the form. The rationale behind the process is that doing so increases the quality at the branch-level. Does your respective institution handle things in a similar manner?

The last bank I worked at was much smaller than the one that I work for now.

At the last bank all errors on CTRs required a new form to be completed by the teller. This was a good way to keep the tellers really paying attention to what they were doing when submitting a CTR to us. However, it did have the potential to hold us up if they were not prompt on getting the new form sent in. As a result, there were times when we combined the two options you present. We made the necessary corrections if we could in back room but still made the teller do the form over again. One of my personal favorite tactics.

At my current institution it's simply not really a good time management option to require 'redos'. The way the bank is structured does not lend itself well to the practice. All corrections are made backroom and any specific teller or branch that generates a higher error rate is given refresher training on proper completion.

Note, this is only applicable to errors that we *can* correct. If the problem is missing information, that's obviously something that is sent back to the front line to get cleared up A.S.A.P.

We kick the errors back to the Branch Managers to fix. We monitor if a teller/branch has repeat problems that would require training. By having the branch fix the problems, they are aware of what the tellers are doing wrong, and in the case of missing or incorrect information on the core system, they make system updates to prevent future errors with the same data. This has really increased the accuracy of the CTR's and frees us up to do more important stuff, like suspicious activity reviews.

Our form is electronic and we have the preparing branch correct.

As the BSA Analyst at my bank, I can tell you that my life has become 1,000 times easier since we centralized our CTR process. The branch employees gather information and enter it into the system, but I actually complete all of the forms myself.

We have saved a fortune on white-out!

I would kick back significant errors to ensure problems to not recur or provide copy of corrected CTR to Manager for retraining (if filing deadline was tight). Insignificant errors, such as typos, transposed numbers, would be correct by BSA staff prior to filing.

I actually just pushed the entire CTR process backto my branches. They are in charge of completing the CTRs & submitting them electronically. I then audit them & if there are any errors - it shows up in their review. Because the Manager is ultimately responsible - they are much more careful now to complete everything correctly the first time. I of course am available for questions prior to final filing.

This decision was made based on two years of error free CTRs & the fact we maybe file 15 a month. Plus I started wearing all these "fun" hats & I don't have any extra staff.

Amen on centralizing the CTR process. IMHO it is clearly a back office function.

(not as) newbsa - If branch-based filing is working for you, great. I have seen it tried, but never successfully. And I have seen very few managers that give a [rodent's derrière] about operational issues such as CTRs. They are incented for sales, deposit and loan growth, not CTR accuracy.

Lack of CTR accuracy removes their incentives for sales, deposits ... etc ... When it starts hitting their pocketbooks they'll start to care

A centrallized process does work better 99% of the time. However at my particular bank - right now - it is the best option.

OUR BSA functions (CTR and CIP) were centralized several months ago and it has been a lot smoother, particularly the CTRs. When identifying information is missing, the banking center employee is contacted to obtain the info. This happens on multiple transactions for a business where the conductor is a non-customer.

Now on a different BSA topic: As for CIP exceptions....that's our "headache"!! But the EVP/Retail has tied CIP exceptions to the quarterly incentives for the retail personnel...if they have a CIP exception, no incentive!!!! Now if the "powers to be" would only do the same for our lending personnel......

I am at a mid sized bank and we use Patriot Officer & file electronically from the back office.
However, if there are errors, the branch corrects them & we review & complete the CTR's.
I would not be comfortable allowing the branches to file directly.