In a quarterly review one of our high risk customers, I noticed that we didn't file a CTR back in October when we should have. It was a circumstance where one person brought in cash in excess of $10,000 and deposited to multiple accounts with different owners. Do we just file the CTR as it should have been filed 2 months ago or do we have to include a cover letter explaining that we inadvertantly overlooked this and are late filing? I never had this happen before and am looking for guidance. Thank you!

You should just file the CTR.

More importantly, the bank needs to find out how this happened and implement changes so it doesn't happen again. Regulators will want to know what you did to avoid having the problem again.

One person with over $10,000 should be one of the easier CTR situations to spot. It sounds like a branch training issue.

Right, I agree it's a branch training issue. Since out automated reports don't aggregate this type of situation due to different account owners/TINs. We need to hammer home to the tellers that when one person comes in or goes out with more than 10K, we need to do a CTR. Thanks for the input!

Also document for your internal files how you found the error and the steps that you took to prevent a future occurrence.