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#1763747 - 12/04/12 07:02 PM CTR Aggregation --Disagree with Examienr
CantBeShocked Offline
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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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#1763786 - 12/04/12 07:47 PM Re: CTR Aggregation --Disagree with Examienr CantBeShocked
John Burnett Offline
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John Burnett
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"CIF relationship" means different things to different people. Remember that there's no actual regulatory requirement that you aggregate unless you have the capacity to do it. Without knowing more about some of the aggregation scenarios your examiner thinks you ought to be catching, I can't offer you much of a response. Absent that additional information, my initial reaction is that the examiner is engaging in some creative (some would say "wishful") thinking, and hasn't given you any regulatory citation that backs up his/her suggestion.

So if you can illustrate the sorts of relationships the examiner thinks you ought to be setting up for aggregation, we can offer some more helpful reactions.
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#1763796 - 12/04/12 08:19 PM Re: CTR Aggregation --Disagree with Examienr CantBeShocked
CantBeShocked Offline
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CIF relationship as in Husband / WIfe, Business / Business Owner, Brother/Sister.............WHEN they exist.

She also mentioned having a way to enter and track transactor on all cash transactions - perhaps over $3000 - and aggregating by transactor at the end of the day.
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#1763806 - 12/04/12 08:34 PM Re: CTR Aggregation --Disagree with Examienr CantBeShocked
John Burnett Offline
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John Burnett
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She's trying to get you to add to the aggregation you're doing (you've said as much). What's missing is the "why." Sometimes examiners offer suggestions when they are concerned that a compliance program is dated or incomplete. Other times, I believe they offer suggestions just because they think it's a good idea, without any specific reason for pushing the issue.

If someone sees some real utility in making that sort of connection for purposes of aggregation for CTRs, I'd hope they would chime in on this thread. Personally, I think it's an over-reach by the examiner.
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#1763807 - 12/04/12 08:36 PM Re: CTR Aggregation --Disagree with Examienr CantBeShocked
CantBeShocked Offline
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At the very least you've made me feel better because those were my thoughts exactly. HOpefully someone will chime in - if it is possible that they do aggregate in some other manner than by TIN or Account #.
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#1763856 - 12/04/12 10:11 PM Re: CTR Aggregation --Disagree with Examienr CantBeShocked
rlcarey Offline
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Galveston, TX
I'm with John, this is a real over reach. So you get these reports of aggregation by CIF relationship, then you have to research every one everyday to make a determination of whether to report. Much work = little to no outcome. As you said, you already aggegate by SSN/EIN which is the standard in 99.9% of banks and I assume you have procedures to aggregate by common conductor (even if at the teller line). A bank only has to make reasonable efforts to aggregate deposits.
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#1763864 - 12/04/12 10:28 PM Re: CTR Aggregation --Disagree with Examienr CantBeShocked
CompliKat Offline
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I believe you are in a Gulf state... are you an FDIC bank? I get the feeling I may have just had the pleasure of entertaining your examiner!!!!

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