The FDIC has recommended that I look back at 18 months of CTRs filed and referred to a report she pulled from FInCEN that showed the CTRs filed and the amounts of the CTRs. I looked at the report that I can pull but it does not list $ amounts. Does anyone know how to pull a report that will include amounts? We are to look for patterns and see who brings in the most cash.
Thank you.

We wouldn't need CTR's to do that, our cash reports we look at daily would reflect that. Do you have something similar? Also, our AML system would fire an alert on anything suspicious (cash wise) so personally I would argue this recommendation and have them defend its usefulness.

We do review our cash report daily as well. Just trying to make use of FInCEN and their reports. May not agree to do it if I can show that this doesn't provide us with useful information. I can look at the CTRs filed and see who our most active customers are. Maybe if I cannot pull that report like the one she showed me, she won't follow through with her recommendation.

I don't believe FinCEN provides analytical reports from their BSA E-Filing website. Those would have to come form your end of the filing. We currently use a manual spreadsheet that we track our exempt cusomers daily and also all CTRs filed get logged with customer and amount. Our automated software has the capability also, so we will be switching to that in the near future.

It's both wise and courteous to demonstrate interest and consider an examiner's suggestions, some of them know stuff. However, if the technique replicates information you already have, being polite doesn't require you to waste limited resources. Your examiner has no way to "follow through" with a recommendation unless she puts it in the written report and this one is too specific to be appropriate unless she can point to activity you missed that its use would have brought to your attention.

I'm curious about the existence of a FinCEN report like the one your examiner touts, but would instantly point out that P*Q's is more valuable as it could include amounts below the reporting threshold. Some of those transactions are more interesting than those that were reported.