We are being challenged regarding FTE's for CTR filing &
BSA/AML Overall.

We are a $2 Billion bank

We file about 380 CTR's per month and have between .50-.75 fte dedicated for this. We are not batch filing at this time as we do not understand the pros & cons very well. Those that batch file, can you explain the pros? Those that don't the cons?

Overall for CTR, SAR's, AML monitoring, High Risk Monitoring, MLR filing, and fraud we have approx 3.5 fte

Can you tell me how we compare and/or any guidance or references on fte measurements for BSA would be greatly appreciated.

Sorry that's 380 CTR's per QUARTER

Previously I was a BSA Officer at a 2 Billion 21 branch bank. We had a similar number of CTRs. Had one FTE doing CTRs

For a third party to intelligently question your FTEs devoted to CTR filing you would have to have some deficiencies in timing, accuracy, something. There are no benchmark figures because some systems are more efficient than others; i.e. one FTE might be enough in one bank, but two would be hard pressed in another which had the same filing load.

Are they offering a tangible criticism?

The first issue is batch filing is do you have the data processing capability? If not, it's largely a moot point.

I am a $1B bank, 4 branches, about 300 CTRs per YEAR. Therefore I utilize a Teller who handles all of it for me. (She's brilliant). Takes her maybe a half hour to 2 hours a day depending on the day.

At a prior bank, I had about 300 CTRs per MONTH and we had a full time FTE when we were paper filing, but it quickly lowered to half an FTE (if that) once we filed electronically through software.


If you're still on a paper trail - I could see half a FTE being difficult, but since everyone's going electronic soon, you may be on the right track.

At the Bank where I had one FTE we paper filed.

We are $1.6B, 23 branches and file about 160 CTR's per month - electronic batch filing. We spend an average of 20 - 30 minutes per day on CTR's.

I guess it all depends on your system and training to ensure accurate information at the time of the transaction(s).

As previously noted, the assessment of your staffing needs should be based on the ability of your team to effectively manage day-to-day tasks. You should also consider any anticipated changes in the bank's customer base, especially any anticipated mergers, acquisitions or system changes that could impact your work load. These changes might include implementation of new aggregation or suspicious monitoring software which will require additional man-hours and pull from your existing team resources.

I would consider issues such as:
1) Are CTR and SAR filing deadlines being met?
2) Is there sufficient time to manage on-going customer investigations, particuarly those needed to manage higher risk clients and SARs?
3) Are individual team members provided sufficient time for ongoing personal training?
4) Are you able to keep manuals, risk assessments and staff/Board training materials current?
5) Any bank/resources changes anticipated in near future?

There is no magic staff number. The ability to effectively manage any BSA/AML program varies depending on quality/expertise of team members and resources available to improve efficiencies.

We file about $1,300 a month descrete filing, not batch. I have a part-time employee that handles all of the CTR filing. She works 30 hours a week.

I very much appreciate your feedback. We have not missed any filing deadlines and our OCC Exams have all been good. We are looking at some possible software changes which may streamline our CTR process.