Can you please tell me how your CTR automated system or report aggregates for tracking required CTRs? Via SSN/EIN, via account number, via address, via CIF relationship, etc.
Last edited by The Real Mobo; 12/04/12 07:02 PM.
Our system (a well known national system) aggregates by EIN/SSN. We can also manually add "groups" of related customers when we are aware that one person conductions multiple transactions for multiple beneficiaries - for tracking purposes.
HOWEVER, an examiner is telling us that we should, at the very least, also aggregate by CIF relationship.
I have been processing and managing CTRs since 1992 and have never had this come up and have never had an examiner question how my automated system works.
Any thoughts ??