During a compliance review of CTRs, it was found that our branches are only completing a Section A for the individual conducting the transaction on their own behalf. They are not reporting all account holders on whose behalf the transaction was conducted. Would we need to go back and file corrected copies to FinCEN?

What if other information is found missing from the forms? Several forms are missing information required to complete section III. Missing routing numbers, signatures, Examiner code.

Please advise...I only reviewed one branches CTRs and found over 30 errors for 2004.

FinCEN has never offered any guidance on whether an error must be "material" before the filing of a correction is necessary. Any advice you get here that involves anything less than correcting all of them is going to be based on a personal opinion which your examiner may not share. I suggest you call FinCEN for advice at (800) 949-2732 and document the conversation. (You could call the IRS Hotline at (800) 800-2877, but I am more and more frequently told they do not call back with any degree of predictability.)

Measure the depth of the problem by comparing the number of CTRs with mistakes to the number of CTRs filed by that branch. The variety of errors you describe is more easily attributable to sloppiness than poor training. There is also something wrong with your internal controls, the errors should have been detected by the person who reviewed the forms prior to filing. Before you implement remedial training, check the CTRs filed by a couple other branches to see how widespread the problem might be.

In the interim, i.e. right now, tighten your internal controls to stop the bleeding. Annonounce that all CTRs will be thoroughly reviewed before filing. Any that are incorrect or incomplete will be sent back to the preparer. Repeated errors will result in disciplinary action. In my experience, the single greatest improvement you can make in quality is to tell people their work will be reviewed by others.

Obviously, the end result is to retrain the personnel involved.

I am confused here. If I have a client and he has a joint account with his wife. If he comes in to deposit cash and I have to file a CTR, I always file it under his name only. He is conducting the transaction on his own behalf.

But the wife is also benefitting from the cash deposited so she needs to be in the CTR as well. Page 2.

I'm dead! How bad is this?

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