I have not been at this institution for very long. One of my first tasks was to conduct a BSA compliance review. I started with CTRs. I just completed my review of CTRs completed by our branches for 2004 and found that the branches only completed a Section A for the individual conducting the transaction on their own behalf. Joint owners that benefited from Cash In transactions were not reported on any CTR. Should I file amendments to all of the CTRs filed during 2004 where the joint owners were not reported? Please advise....

I would quanitfy my findings and contact my state's IRS representative at the Detroit Center. I would be surprised if you don't have to amend, this is important information.