From my BSA/AML burden comment letter:
The CTR form and reporting threshold was developed over 30 years ago. At that point in time, $10,000 was a huge sum of money. Also, at that point in time, SQL database and computer technology was in its infancy. However, we still have that same threshold, and the same basic form with many parts and boxes to cover any number of anticipated scenarios. However, no matter how carefully the form is designed, it can still be difficult to properly fill out the boxes to fit an unusual situation. If the incorrect boxes are completed, the financial institution is at risk of a regulatory violation not because the institution does not intend to comply with the law, but because the CTR can be almost as complex to fill out as an individual tax return. Yet, this form must be completed thousands of times each day in financial institutions across the country.
Given the technology that exists today, it would be far simpler for banks to submit a monthly report of all deposit accounts that had an aggregate cash in and/or cash out of $10,000 for the month. The report can be a simple electronic file that consists of:
Account name
Account number
Taxpayer Identification Number
Account address
Total cash in
Total cash out
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'