Maybe this will help. Backfiling determinations are normally the result of a bank improperly granting an exemption to CTR filing. When this happens, the bank is requested to contact FinCEN for a backfiling determination. FinCEN requests information from the bank on the transactions and determines whether or not the nature of the business conducting the transactions and the types and sizes of the transactions would warrant the backfiling of CTRs on those transactions. If it is determined that the transactions should be reported, FinCEN directs the bank to search the transactions for a given period of time and file appropriate CTRs. In some cases, it is determined that backfiling the CTRs would serve no useful purpose, but the bank is directed to file from a certain date forward. In any event, the bank is strongly advised to review its exemption granting process.
Politicians are like diapers. They need to be changed often and for the same reason.