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#2129004 - 05/03/17 05:55 PM CTR-reporting correction to regulator?
Sunshine Banker Offline
Member
Joined: Jun 2012
Posts: 80
Florida
Through self discovery-found an error on CTR-entered incorrect state for ID. We have made the correction and notified FinCen.
Do we also contact our regulator, noting the correction?

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#2129014 - 05/03/17 06:04 PM Re: CTR-reporting correction to regulator? Sunshine Banker
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
No need. Document the error, that you identified it, checked to see if it resulted from a missing or inadequate control, and that you filed the amending CTR.
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#2129021 - 05/03/17 06:09 PM Re: CTR-reporting correction to regulator? Sunshine Banker
McFly Offline
Member
Joined: Nov 2016
Posts: 75
No - that would be overkill IMHO. The regulator would be more interested in whether you have adequate internal controls to prevent CTR error occurrence. As you have identified an error, I would consider whether those controls could be strengthened.
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#2129033 - 05/03/17 06:33 PM Re: CTR-reporting correction to regulator? McFly
Sunshine Banker Offline
Member
Joined: Jun 2012
Posts: 80
Florida
We have very limited occurrences with corrections-this one slipped past and was corrected within a short period of time. No issues in the past with our CTR filing program from a regulatory or third party reviews.
According to the BSA E- Filing Helpdesk, Instructions for Backfiling and Amending CTR , Issued September 10, 2013. We need to notify our regulator. I explained this was not a backfiling, our regulator did not discover this error. The only error ws the state for the ID.
I have not notified the regulator in the past-thought this might be something new?

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#2129046 - 05/03/17 07:20 PM Re: CTR-reporting correction to regulator? Sunshine Banker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
Amending a single CTR does not require that you notify anyone. You just file the amendment and move on.
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#2129063 - 05/03/17 08:18 PM Re: CTR-reporting correction to regulator? rlcarey
Sunshine Banker Offline
Member
Joined: Jun 2012
Posts: 80
Florida
That's what we did and moving on!

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