When FinCEN revised the CTR process and exemptions, it made clear that it didn't want extra CTRs. The goal was to reduce the number of filings. The law enforcement types are really only interested in the higher amounts. However, you could have a situation, such as structuring, that calls for filing a Suspicious Activity Report. In fact, FinCEN has made clear that for $9,999 cash transactions, they want the SAR but not the CTR.