This strictly may be a software vendor issue but we can't find anything in the FinCEN instructions to verify that the change is correct.
Last edited by The Real Mobo; 02/22/13 05:50 PM.
Scenario - you have a customer who makes a deposit into his checking account for $12,000.52 and a loan payment on his personal loan for $10,000.09. In the past, you previously totalled the two transactions together ($22,000.61) and then rounded up to $22,001 for the CTR.
HOWEVER - our CTR software rounds the deposit to $12,001 and the loan payment to $10,001, places each amount on the correct line in on teh CTR and then totals them to $22,002.
We cannot find anything in the FinCEN tech specs for the new form or any instructions that state that individual transaction type rounding is appropriate.
Hoping somone here has some input. We are also calling our vendor to ask why they are doing it this way.