I recently had to submit my first FinCEN Directed CTR Backfiling. On the instructions for Backfiling and Amending Currency Transaction Reports issued October 27, 2014, the guidance states:
"After the financial institution has filed the FinCEN CTRs, it must send a letter confirming that the reports have been backfiled and/or amended. The letter should be addressed to FinCEN with copies sent to those federal and state agencies that examine the financial institution's Bank Secrecy Act/Anti-Money Laundering Compliance Program"
Unfortunately for me, I became the BSA Officer after the most recent FDIC examination of by institution. As a result, I do not have contact information for our examiner directly, so I reached out to our regional FDIC office in order to obtain an email or physical address to send a copy of this explanation.
The individual I spoke with at the FDIC stated that they did not have anywhere for me to send a copy of this letter, that I did not have to send it to their office, and further provided me with a Currency Transaction Report Backfiling or Amendment Checklist dated May 2012.
Am I way off, or is something wrong here? I'm assuming I can just document the email correspondence with the FDIC individual I spoke with in order to cover myself in a future examination, however the fact that the Division of Banks from the state examination level was able to provide me with a contact office to send the letter tells me that I should truly be sending it to the FDIC as well.
Life is like a bicycle. To keep your balance, you must keep moving.