When you determine there's an error worth amending on a CTR, how do bankers out there handle the amendment? Meaning, do you just amend the CTR in BSA E-Filing accordingly and put a note to file, or do you contact FinCEN letting them know you're amending the CTR? (I'm asking this for bankers who have actually filed an amended CTR, not asking best practice, or what guidance says, just which of the two options do you do/have you done).

You just amend - you would contact FinCen if you didn't file at all for a back-filing determination. I'm not sure what you mean by an " error worth amending ". As far as I am aware that would be any error, regardless of how minor you think it might be.

Funny that we had that question last year about an amendment we needed to do, we contacted Fincen and below is what they told us we had to do. Is it silly? Yup but we weren't contacted saying we didn't have to do it.

If you amend a CTR you need to notify FinCEN as well as our federal and state regulators. The letter must include: The Bank’s legal name and address, your name, phone number, email address, and the following information for each amended CTR- the original DCN and new/amended DCN, date of the actual transaction, amount, and reason for amending.

That language is taken from the "Instructions for Backfiling and Amending Currency Transaction Reports"

https://www.fincen.gov/sites/default/files/shared/BackfilingandAmendingCTRs.pdf

If I discover a systemic issue (wrong RSSD # on every CTR, name misspelling on a CTR temple for a business on which I have filed multiple CTRs) I may contact FinCEN to ask if I need to fix all the previous CTRs or fix going forward. If I am directed to amend all previous CTRs due to systemic issue, then I am using these instructions, sending letters, etc.

For a single CTR where I discovered I forget to include a $500 currency exchange and file an amendment to update the amount, I'm not even contacting FinCEN for the determination, I simply file the amendment and call it a day.

Thanks, P*Q, your answer is what I was looking for. We encountered that same language when asking FinCEN if a particular situation warranted an amended filing. I have to say that doing BSA for twenty years, I have never ever heard of that requirement, and yes I agree that it's silly to do all that paperwork for an amendment. (and we're only talking about amending two CTR's...just two).