I am posting annon due to the subject. What if a bank performs the annual review but just realizes it neglected to file for the Biennial Renewal? We have decided to submit the renewals (yes, we missed more than one). However, transactions occured that technically required CTR filings? Will we face penalties/fines, etc?

What would you do?

Only one option: come clean. File the DEPs now and do not indicate they are renewals. That will cover the CTRs you should have filed in the last 30 days. Call the Detroit Data processing center and ask for a backfiling determination. They have a standard form for it, so you are obviously not the first.