We have just been through another exam and have been told that we are required (according to the manual) to report on filed CTRs to the board every month. We do not file a significant number of CTRs and are not located in a high drug trafficking or financial crimes area. We have always included the information, along with trends, in the annual security report to the board. Have I missed something in the manual? Also, they have given us 90 days to provide training for a director who was sick the night we trained the rest of the board last year. This seems a little out of line given that our overall program has been deemed satisfactory. The director did receive training in the two prior years and will receive it again this year. Are others hearing these same things from their examiners?

CTRs or SARs?

I am with KC - - Are they really saying to report CTRs monthly, or is it SARs?
Also, about the director not receiving training - yes it is nit picking, but in todays BSA world there is no room for human error.
So, someone missing training - is someone missing training ; this means you have to do an analysis of training provided and make sure everyone recieves training (specific to their job duties) and that what was covered in the traninig is adequate.

If they are saying that monthly CTR reporting to the Board is in the exam manual, I'd ask for a page number. I've never heard that.

that is not in any manual I have ever read!

Yes, it is CTRs and our reaction was "why". SARs are already reported to the board monthly. As for requiring training within 90 days for the director who missed it last year, it seemed nitpicking considering that he has received training twice in the last three years (including quizzes), will receive it again this year, and we were not cited for any issues other than these. It's also not like there were any major changes that impacted us, plus he's a director who is very conscientious about his fiduciary duty. In fact, he will likely receive training two months in a row now this year. Sorry, sometimes I just need to rant.

I report SARs, CTRs, & High & Med Risk #'s along with a small training paragraph to my board monthly. This way if I have one missing it doesn't matter because they get trained all year long. The examiners love it.

I fully understand.

I report to the "audit committee" quarterly on # of CTRs filed and # of SARs filed and the information of the types of SARs filed, no names mentioned, as well as details on training to all staff (job specific), then I have an annual BOD training, this is adequate for our Institution. We are 1.8Billion in assets, we have 22 branches.

We have a monthly BSA committee meeting. Minutes include #CTRs, #SARS (with notation info on file with Comp Dept.), any internal,external exam reports, names of acts exempted for first time....minutes go to audit committee. Separately, whenever we file a SAR, this is reported to board.....manageable, even for a small bank like ours.

It this a Federal examiner? Is it going to appear in the ROE? If not, I would say that you will take the recommendations under advisement. If they are going to appear in the ROE, I would kick this up to the next level. Anything else is just that specific examiner's opinion.

If this is not a Federal regulator, I suggest you look for a new auditor.