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#1516602 - 03/02/11 08:16 PM Audit on CTR's
katbg Offline
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katbg
Joined: Mar 2010
Posts: 18
North Florida
I need some help..........BSA Audit in progress.....auditor printed out list from FinCEN showing all CTR's etc. The auditor just mentioned to me that for the month of January, I have CTR's on file that FinCEN has not registered...around 10 of them.....has anyone had this happen before? I did not have an explanation because all I know is I mailed the CTR's....we are not set up for e filing just yet. The auditor found it odd that it was just the month of January and they have received 2 for the month of February.....

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Audit
#1519653 - 03/09/11 08:58 PM Re: Audit on CTR's katbg
K8T Offline
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K8T
Joined: Sep 2003
Posts: 196
I have fallen down the rabbit ...
Do you send the CTRs certified mail? can you prove that you sent them? Before we filed electronically, we always had a return receipt.
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#1519785 - 03/09/11 11:21 PM Re: Audit on CTR's K8T
NeBanker Offline
Gold Star
Joined: Jun 2008
Posts: 408
I found this exact problem when I conducted a CTR audit last year at my bank. We stated we filed them but FinCEN had no record of them. We did not do certified mail so we had no proof of mailing them. Thatís when I strongly suggested efiling.

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#1521083 - 03/13/11 02:53 PM Re: Audit on CTR's katbg
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Audit? Auditors don't have access to the BSA data base; they cannot obtain baseline information for comparison to your file copies. Examiners do. I referred to an examiner as an auditor once. It was a few decades ago, but I still remember the tone of voice he used when he corrected me.

If CTRs were not received in Detroit, examiners generally take the perspective that they were not filed. Sending paper CTRs return receipt requested doesn't prove what you need to prove. I've seen examiners just shrug and say, "The receipt proves you mailed them an envelope and they got it. It does not prove what was in the envelope." My experience is they will cite you for not filing the CTRs.

Given the ridiculous way paper CTRs are handled; i.e. from Detroit they are sent to an Indian reservation in the Dakotas for input, it's amazing that more of them don't go amissing.

Here is a pdf copy of the ppt slides from the FinCEN webinar on the benefits of e-filing. One of those benefits is that you automatically have proof of filing.

It's time for the hold outs to just sign up... Problems like this are just a waste of everyone's time.
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#1524790 - 03/21/11 08:06 PM Re: Audit on CTR's Elwood P. Dowd
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
how the heck is the auditor getting access to what has been filed with FinCEN? news to me... or did you mean examiner?


just convert to efiling. it was the easiest thing i ever did and you will have a record of it.
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