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#1095308 - 12/10/08 09:42 PM CTR Questions
Mrs. Rizzo Offline
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Mrs. Rizzo
Joined: Mar 2006
Posts: 10,392
Curled up by the fire...
I'd like to get a little feed back on these questions:

#1 - Is it a regulatory requirement that late filed CTR's go before the Board?

#2 - When it comes to CTR's for non-customers, how do you verify the customer? Just basic CIP procedures?

#3 - Does anyone use InSight Teller from ITI? And if so, is there any type of notification or block that can be utilized to flag when a CTR is required?

#4 - How is accountability in your FI handled for misfilings, errors, etc?

Thank you in advance for your time and your thoughts!!
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#1095343 - 12/10/08 10:05 PM Re: CTR Questions Mrs. Rizzo
John Burnett Offline
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John Burnett
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Cape Cod
1. No. But if an audit detected a pattern or practice of late filing, the board should hear about it before the examiners tell them.

2. You are required to verify the name and preferably the address using a form of identification normally accepted for check cashing. The ID must include the individual's name and preferably address.
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#1095347 - 12/10/08 10:12 PM Re: CTR Questions John Burnett
TXBSA Offline
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TX
#3. There is a notification that can be turned on through InSight. I am not exactly sure where to turn it on though. The system can track multiple transactions at multiple branches as well. Check with your support staff to find out more about it.

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#1095406 - 12/10/08 11:12 PM Re: CTR Questions TXBSA
Mrs. Rizzo Offline
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Mrs. Rizzo
Joined: Mar 2006
Posts: 10,392
Curled up by the fire...
My reasoning for #3 was that "Teller" took 3 deposits, 1 right after the other and didn't file a CTR. I'm not really sure what the circumstances were around them but I was just curious why InSight couldn't prompt her on the 3rd one or something.

Also, does anyone use any type of checklist for filing CTR's? What about address discrepencies? I'm thinking it all may be a matter of requiring additional documentation and more thorough training for our branch staff.

We seem to keep seeing the same errors cry

(Thanks for the input!!!)
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#1097679 - 12/16/08 12:14 AM Re: CTR Questions Mrs. Rizzo
Mrs. Rizzo Offline
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Mrs. Rizzo
Joined: Mar 2006
Posts: 10,392
Curled up by the fire...
Bump...Anyone??? #4???
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#1097927 - 12/16/08 04:43 PM Re: CTR Questions Mrs. Rizzo
BrendaC Offline
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BrendaC
Joined: Sep 2001
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Sweet Home AL
Years ago, before we were able to automate CTR preparation, I utilized a daily branch CTR report to identify reportable transactions identified by each branch. Those branch reports, along with computer-generated cash aggregation reports provided a total picture of our CTRs each day. Send me a PM with your email address if you would like a copy of the form.
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#1098495 - 12/17/08 02:22 PM Re: CTR Questions BrendaC
rdelgado Offline
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Joined: Dec 2005
Posts: 116
#4: At the previous bank I worked for, there was a stricter stance on these errors than at the one I currently work for.

Bank A (old one) tracked all CTR and BSA related errors through the compliance department and supplied a summary sheet to HR annually to be included in individual employee performance reviews. This way these errors played a role in determining pay increases and employment status (usually the 'worst' that happened was probation and then only when errors were repeat and there were other deficiencies in the employee evaluation). To be honest, most employees who had unsatisfactory error rates on BSA related responsibilities were also found wanting in other job functions...so it's hard to say how accountable employees were for direct BSA violations alone.

Bank B (current) takes a more 'helpful' stance than straight disciplinary actions. We handle it here through constant training. On the proactive front, we do orientation training upon hire - which is very overview. After the employee has made it through their first 90 days (type of probation period) and have taken online training courses assigned to them, we do enhanced training that requires the impacted employees to come to the operations center and they are trained by the BSA department staff. Beyond that, branches are required to include three BSA 'bullet points' at every staff meeting (monthly) - which we sometimes make suggestions on when we see 'problem employees' at a specific branch. And finally, the annual BSA training that is required by the regulation is done via online courses assigned based on job function and BSA responsibiilty.

If, after all this training, we find a 'repeat offender' we will generally schedule in depth one on one training with that person and/or visit that branch to do additional training if the branch manager thinks it would be beneficial to do so (worth the time). But again, I find that here we have similar findings with repeat offenders as at my previous bank...if an employee is *seriously* lacking on BSA compliance, they are usually lacking in overall job performance.

Reprimand and termination are branch decisions. To my knowledge we have never had cause to severely reprimand or let someone go based strictly on BSA related issues.
Last edited by rdelgado; 12/17/08 02:25 PM.
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