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#1990341 - 01/22/15 03:52 PM Amend CTR filing to include "retired"
ALW Offline
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Joined: Dec 2014
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Upon reviewing a CTR filing, I advised staff to revise "retired teacher" to "teacher." After re-reading the FINCEN FAQ, I realize the use of the non-descriptive "retired" is acceptable as we had a specific occupation to accompany.

Should an amended CTR be filed in this situation to include "retired"?

Also, does filing amended CTRs look bad to examiners?

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#1990377 - 01/22/15 05:03 PM Re: Amend CTR filing to include "retired" ALW
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Not worth amending. Train and go forth.
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#1991195 - 01/26/15 10:37 PM Re: Amend CTR filing to include "retired" ALW
WonderWoman Offline
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Joined: Mar 2007
Posts: 2,108
gone fishin'
Agree with Randy that this one is not worth amending. See the updated exam manual - Section T. It lists out what is considered a primary & secondary error.

For your second question ... yes it could show an issue with training, data quality, etc ... depending on the volume or severity of the amendments.
Last edited by WonderWoman; 01/26/15 10:38 PM.
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#1991197 - 01/26/15 10:46 PM Re: Amend CTR filing to include "retired" ALW
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
For your second question ... or it could show that your internal control processes are working as designed.
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#1991201 - 01/26/15 10:54 PM Re: Amend CTR filing to include "retired" ALW
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
From current experience with examiners - too many amendments can show your processes are not working as designed. It may mean you need to add additional quality checks before the CTR is sent.

Again, it depends on the volume & severity of the errors.

For example: if you file 100 CTRs with no RSSD number, that is a data quality issue. if you file 100 CTRs with no occupations, that is a training issue.

I am not saying you shouldn't amend - self identification of an error is always better than an examiner finding it. Just be prepared to show how you will prevent it from happening again in the future.
Last edited by WonderWoman; 01/26/15 10:55 PM.
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My opinions are my own, and not that of my employer.

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