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#1815849 - 05/20/13 06:30 PM Amend CTR for wrong Issuing State?
rachelchri Offline
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Joined: Aug 2010
Posts: 165
Would you have to amend a CTR if the Issuing State for the customers ID was filed wrong (Example: Washington instead of Wisconsin)?

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#1815858 - 05/20/13 06:39 PM Re: Amend CTR for wrong Issuing State? rachelchri
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,014
Illinois
The only time I'm calling the Helpline for a backfiling determination is if I have a recurring error that has taken place over an extended period of time. If we're talking one error, better to file the amendment now than risk having an examiner ask you to later. (i.e. If it's wrong and you know it's wrong...fix it.)
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#1815932 - 05/20/13 08:01 PM Re: Amend CTR for wrong Issuing State? rachelchri
banker1976 Offline
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Joined: Nov 2005
Posts: 342
Mid-Atlantic
I agree with BrianC. If you have come across this yourself whilst reviewing CTR's, file the amendment. Better that you find it and amend than an examiner find it. At least amending the report will show you are proactive in reviewing the accuracy of filed CTR's.
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#1815982 - 05/20/13 10:04 PM Re: Amend CTR for wrong Issuing State? rachelchri
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Agreed. Reporting the incorrect state could result in a "miss" by law enforcement involved in an active investigation. I would be proactive and correct. I would also document in my notes how it happened and the step(s) I took to ensure it didn't happen again.
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#1816019 - 05/21/13 10:04 AM Re: Amend CTR for wrong Issuing State? rachelchri
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Understandably, there are no published standards saying when amendments to a CTR are necessary or unnecessary. The only possible source of advice that an amendment is unnecessary is a call to FinCEN.
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