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.
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 ??
Last edited by The Real Mobo; 12/04/12 07:02 PM.
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