Concerning e-filing CTR's, do you have a second person review them before you're submitting them? Our procedure before electronic filing was to have a second person review them before they were mailed. We were able to make any corrections before they were sent. We also keep a paper copy for when examiners request them. Just curious to know if anyone is doing this with e-file or can we drop the extra steps?

We're not, but we don't file that many. We are still printing and keeping a copy; I just write - in yellow - "EFile" and keep them in the same notebook with the others that were mailed. We have a compliance audit next week, so if anything comes up there that might be helpful, I'll share.

My staff does all the research for the CTRs, fills them out and saves them to a BSA Server. Then, I go in there to review them before submitting to the website. . .when it works. It's pretty much the same procedure we used when we did paper filings.

This is what we do:

1. The teller who conducted the transaction completes the CTR & e-mails it to the teller supervisor.
2. Teller supervisor reviews it for accuracy & e-mails it to me.
3. I review it for accuracy & submit.

The teller that took the transaction completes the CTR and emails it to the BSA Department. I then review them for accuracy. If there is an error I email the teller back with a list of what needs to be fixed. Once the CTR is correct I submit it. We have a file on the computer that we save them to.

Even though we are electronic filing, I still have a second tier review in place before submission. I have an 1 person in my dept. who initially receives CTRs from tellers and also prepares CTRs for multiple transactions. She works out all the questions and errors so when they come to me they are ready to file.

Here's how the review process works:

I. We used to discrete file each CTR:
a. BSA clerk got the CTR ready, signed with her pin. Then placed electronic CTR in a particular folder on our network. Gave CTR a file name example "ABC Co 6-8-11"
b. I would review CTR. If everything was correct, I added my initials to the file name on the drive to signify that I had reviewed. Ex. "ABC Co 6-8-11 KM"

II. We now have an automated BSA monitoring system, and CTRs are batch filed. Within our system, there is a place to write notes on each CTR, so I review each CTR and noted "Approved for filing KM 7-3-12".

As far as paper copies - FORGET IT! We store everything electronically. Recently had an OCC exam - request list said to provide 2 years of CTRs. I provided them a list, told them we would produce any CTRs they wanted to see. Examiners never asked for a single one.

Thanks for all of your input! I'll pass it on We're new to e-filing and trying to get prodecures in place. Enjoy your weekend.