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#1959947 - 09/08/14 12:30 PM Backfiling CTR's
tede0808 Offline
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Joined: Jan 2014
Posts: 79
We have a few CTR's to backfile on separate individuals. I have contacted FinCEN and received the CTR backfiling checklist. My question is do I complete this document for each CTR or do I complete one form to send with the letter of how it occurred and what steps have been taken? I have not been able to find any instructions or examples, I guess because this should never happen especially to multiples. I would appreciate any info. Thank you.

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#1960304 - 09/09/14 02:01 PM Re: Backfiling CTR's tede0808
rlcarey Online
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rlcarey
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Galveston, TX
If you missed a small number of CTRs just file them. You don't need a determination.
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#1960387 - 09/09/14 03:54 PM Re: Backfiling CTR's tede0808
tede0808 Offline
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Joined: Jan 2014
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Thank you rlcarey. I will say it, it's 32 and FinCEN has already been notified and documentation sent to us.

Each time I read the "checklist" document I get more confused. "Complete all of part II and III for each individual involved in this request". So if a husband and wife had a CTR transaction, I need to complete a Backfiling Checklist for each of them, correct? And that would also be true of a business that had someone conduct a transaction on their behalf? Is all of this correct or am I reading to much into this?

I don't want to add a mistake to another mistake...

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#1961481 - 09/12/14 01:43 PM Re: Backfiling CTR's tede0808
tede0808 Offline
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Joined: Jan 2014
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Can't seem to win. All 32 backfiled CTR's were submitted. Went back through copies and one was not checked for backfiling (initial was checked). Should I just document this on my paperwork. It is on my backfiled list with the BSA Identifier listed and I will be submitting this list to FinCEN. I know this question may be very basic to some, but I am uncertain. Thank you.

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#1961538 - 09/12/14 03:28 PM Re: Backfiling CTR's tede0808
rlcarey Online
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rlcarey
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Galveston, TX
Just amend it. Amending a CTR in the electronic format is easy.
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#1961563 - 09/12/14 03:53 PM Re: Backfiling CTR's tede0808
tede0808 Offline
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Joined: Jan 2014
Posts: 79
Thanks for responding. I was thinking about that, but if I amend it and put in the BSA Identifier, where would I notate that it should have been a backfiled CTR and not an initial CTR? Since that is the mistake I am trying to correct. Thanks.

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#1961582 - 09/12/14 04:10 PM Re: Backfiling CTR's tede0808
rlcarey Online
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rlcarey
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Posts: 83,219
Galveston, TX
Oh - yeah - hard to amend and change at the same time. I would just let it go.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1961594 - 09/12/14 04:25 PM Re: Backfiling CTR's tede0808
tede0808 Offline
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Joined: Jan 2014
Posts: 79
Ok thanks. I will just note on my side. I appreciate your help.
Last edited by doubleas; 09/12/14 04:28 PM.
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