I'm in operations and have been told that the record keeping for the CTR's and response to questions is an opeartion function. I believe it should be with the Compliance Department. The CTR's are completed by the branch and then sent to the back office to send to the Treasury. Any thoughts

The Teller Supervisor is also my Assistant BSA Officer. So while it's her tellers that create the large cash transaction forms and her deputy that actually efiles the CTRs, overall responsibility for monitoring and oversight is mine as the BSA Officer. And if there are any questions they are directed to the Assistant BSA Officer or myself. I think either of our scenarios will work, provided that the BSA Officer has oversight and is monitoring on a regular basis that the filing is being done.

Who does the CTRs is not as important as making sure they are completed and filed accurately and timely. Some banks have them processed in the BSA Department. Others have them done in Branch Administration, while others have that job housed in Operations.

It is the bank's responsibility to have a good process; where the work is done is up to the bank.

I agree with MS, the process can be handled any number of ways as long as it works. That being said the larger the organization the better it usually works for centralized compliance to maintain the records. In smaller banks operations can handle it without problems. But whatever works for your bank.

Actually, at very large banks I have experienced the processing done in an operations area. The larger the bank the more likely there is automated software that lends itself to ops.

I agree. Based on my observations, in larger banks operations handles all processes from an operational perspective, including CTRs and compliance is totally segregated and tests for compliance with applicable rules and regs.