We've had a discussion at my FI about the dollar threshold in our core system to collect conductor information for CTRs. Our current setting is a cash transaction (in or out) at $7,500, and management is considering changing it to $10,000.01. I'm afraid what will happen is that we won't collect conductor information for our MSB customers and others who would hit the CTR threshold.

What are your settings at in your core system? How do you feel about those settings - should be higher/lower? Any guidance/advice?

I polled some of my peers to answer this question a few months ago and found $2,500 to be the most popular answer. Several were below that amount, and very few above. I think one of the things that drives this is that you need to collect similar conductor information on cash sales of monetary instruments at $3k, therefore many select a number just below that to ensure that they cover the monetary instrument log requirements.

Ours is $2,500.00. My last bank was $3,000.00 (because of MI's), but since it was already $2,500 when I got here, lower is better for BSA. It's a balancing act between BSA and the branches, that's for sure. Your level is already very high...but I guess it depends on how you are tracking aggregation and reporting without the conductor info and how often you run into reporting issues because you don't have conductor info.

I had found $3,000 to be the consensus when I polled a number of colleagues, but it will depend on your circumstances.

In most cases the $3,000 is sufficient to 'catch' most aggregations that go over $10,000, but not cause too much unnecessary work for the branch staff. If we do get a number of cash transactions for one customer under the $3,000 limit that go over the $10,000, I just give a call to the branch and ask them 'who did it'.

Our MI recordkeeping only kicks in when someone purchases a cashiers check and captures from $3,000 to $10,000 (obviously anything over than the $10,000 will kick-up to a CTR.

Also, if you do set it at $10,000.01 you may be filing a lot of CTRs where the conductor is unknown and I think that may trigger some questions from an examiner.

The most common amount cited by audiences is $3,000. The yield is more conductor information and, since it facilitates aggregation on conductors, a few more CTRs.

However, I'm not at all sure what real value that represents or where the point of diminishing returns might be; e.g. if $3,000 adds value, why not $1,000? Personally, I'd plug it in at $7,500.

Ours is $3,000 and it seems auditors and Examiners are inclined to be happy with that amount.

This is good information, thank you all for your feedback. I appreciate it.