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#152448 - 01/22/04 04:19 PM
CTR filings
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Anonymous
Unregistered
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I have an FDIC examiner here who is not familiar with BSA/CTR requirements and thinks we are in non-compliance for not aggregating the total of payroll checks cashed by different payees and filing CTRs. I showed her 103.22 (c)(2)on aggregating transactions that they must be on behalf of the same person but she doesn't think that is what it means. HELP!! Where can I direct here
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#152449 - 01/22/04 04:23 PM
Re: CTR filings
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10K Club
Joined: Jul 2001
Posts: 83,352
Galveston, TX
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Tell her to go here and read Q&A 13A: FINCEN Q&A
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#152450 - 01/22/04 04:29 PM
Re: CTR filings
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Anonymous
Unregistered
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Thanks for the information. I am printing it right now to take to her.
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#152452 - 01/22/04 04:40 PM
Re: CTR filings
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Member
Joined: Dec 2003
Posts: 50
Oklahoma
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Quote:
Is this a federal examiner?
Is their a state FDIC that I don't know about...or would that be SDIC??  Just kidding.
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#152453 - 01/22/04 04:41 PM
Re: CTR filings
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Power Poster
Joined: Dec 2000
Posts: 5,184
All over the map.
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Quote:
I think the more pressing question is why an examiner is not familiar with BSA/CTR requirements. Is this a federal examiner?
Inside joke here.....Is her name Kelly?
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On the road again.....I just can't wait to get on the road again.
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#152456 - 01/22/04 04:47 PM
Re: CTR filings
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Anonymous
Unregistered
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Quote:
Where can I direct her
How about to the nearest exit?
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#152457 - 01/22/04 04:47 PM
Re: CTR filings
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Diamond Poster
Joined: Feb 2003
Posts: 2,362
Colorado
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Anon, trust me when I say that this will not be the last time you will get to "educate the examiners".
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Opinions are mine and not necessarily my employer's.
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#152458 - 01/22/04 04:48 PM
Re: CTR filings
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Power Poster
Joined: May 2001
Posts: 8,458
Somewhere
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Quote:
Quote:
Where can I direct her
How about to the nearest exit?
Anon, LMAO! 
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#152460 - 01/22/04 06:00 PM
Re: CTR filings
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Anonymous
Unregistered
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Quote:
Anon, LMAO!
Maria,
I confess my ignorance. What's an LMAO? I don't know whether to feel praised or insulted.
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#152461 - 01/22/04 06:21 PM
Re: CTR filings
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Power Poster
Joined: Jun 2003
Posts: 7,655
Florida
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Quote:
Never never forget that examiners make mistakes. . .
There is a decent turnover in field examiners, and most are in a perpetual training.
During our examinations (at a large multistate bank) we had an internal policy of setting a timer and visiting the examiners every hour. This allowed an explanation, a free exchange of topics, and prevented unnecessary questions from being written down and raised later during the exit.
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Integrity. With it, nothing else matters. Without it, nothing else matters.
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#152462 - 01/22/04 06:48 PM
Re: CTR filings
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Power Poster
Joined: May 2001
Posts: 8,458
Somewhere
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Quote:
Quote:
Anon, LMAO!
Maria,
I confess my ignorance. What's an LMAO? I don't know whether to feel praised or insulted.
LMAO=Laugh my a$$ off so I was telling you that your comment was funny.
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#152463 - 01/22/04 07:05 PM
Re: CTR filings
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Anonymous
Unregistered
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As a former examiner I can tell you that the knife cuts both ways...there were many times I had to "educate the banker"...give the girl a break...she's probably brand new like you once were.
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#152467 - 01/22/04 07:36 PM
Re: CTR filings
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Power Poster
Joined: Oct 2003
Posts: 2,548
Southeast
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Quote:
And what the examiner was citing is a pretty easy concept
That may be true, but I think if you do a search on this site, you will find more than a few people who have posted questions on the same type of payroll check situation. Nobody criticized them for not knowing how to handle that particular type of situation.
Last edited by Retread; 01/22/04 07:42 PM.
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#152469 - 01/22/04 07:47 PM
Re: CTR filings
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Power Poster
Joined: Oct 2003
Posts: 2,548
Southeast
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Not at all. All I'm saying is that the examiner made a mistake. Let's give her a break. We all make mistakes and we learn from our mistakes. I bet she won't make that same mistake again. What do you think?
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Politicians are like diapers. They need to be changed often and for the same reason.
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#152470 - 01/22/04 07:48 PM
Re: CTR filings
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10K Club
Joined: Nov 2003
Posts: 12,846
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Quote:
. . .before accusing someone of being non-compliant. . .
We don't really know what form the "accusation" took, do we? She could have just said, "now, why are you not aggregating the payroll checks. . .oh, are you sure?"
As an internal auditor I've been corrected many times, and corrected others many times. I try to not be wrong (there's no money in it  ), but it's going to happen, especially when you work in a field as broad as banking.
I vote we cut her some slack.
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