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#2177351 - 05/09/18 02:45 PM Forgot to check the box
Bec Offline
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So, I forgot to check the multiple transactions box on a transactor that did, in fact, bring in multiple transactions. Of course I filed the CTR already through BSA Efiling. It was a discrete filing. Do I have to wait for the acknowledgement before I can correct it?
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#2177354 - 05/09/18 02:51 PM Re: Forgot to check the box Bec
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Ok, so I took a deep breath and I was able to reopen the submitted CTR. I am able to remove my signature and check the multiple transactions box. Should I now file this as a corrected report, or am I still allowed to call this my "initial submission".
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#2177366 - 05/09/18 03:56 PM Re: Forgot to check the box Bec
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If you already filed it through the e-filing system, it is an amendment, not an initial submission. I would wait until the acknowledgement comes back so you can indicate which CTR you are amending by the DCN.
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#2177373 - 05/09/18 04:07 PM Re: Forgot to check the box Bec
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I was hoping I could use the no harm no foul tactic and do a sneaky double initial submission. You think that is a bad idear huh?
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#2177385 - 05/09/18 04:36 PM Re: Forgot to check the box Bec
ItNeverEnds CRCM Offline
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Originally Posted By Bec
I was hoping I could use the no harm no foul tactic and do a sneaky double initial submission. You think that is a bad idea huh?


Yes, because it will create another CTR, so there will be 2 CTRs with FinCEN for the same transaction.
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#2177388 - 05/09/18 04:43 PM Re: Forgot to check the box Bec
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bummer, stupid check boxes
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#2177399 - 05/09/18 05:21 PM Re: Forgot to check the box ItNeverEnds CRCM
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Originally Posted By ItNeverEnds CRCM
Originally Posted By Bec
I was hoping I could use the no harm no foul tactic and do a sneaky double initial submission. You think that is a bad idea huh?


Yes, because it will create another CTR, so there will be 2 CTRs with FinCEN for the same transaction.


and it is not what the CTR instructions say
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#2177405 - 05/09/18 05:29 PM Re: Forgot to check the box Bec
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Would you be able to point me in the right direction as far as those instructions? I looked on the efiling website, but I couldn't find anything.
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#2177415 - 05/09/18 05:42 PM Re: Forgot to check the box Bec
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#2177416 - 05/09/18 05:43 PM Re: Forgot to check the box Bec
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From pg. 94 of PDF

9. Corrected or amended reports. A corrected report must be filed whenever errors are discovered in a previously-filed FinCEN CTR. Amended reports on FinCEN CTRs must be filed whenever additional data about the transactions are discovered. Both corrected and amended reports must be completed in their entirety, with the necessary corrections or amendments made to the data. In both cases box 1b “Correct/amend prior report” must be checked on the FinCEN CTR. Field 1d must contain the BSA Identifier (BSA ID) assigned to the prior filing. If the BSA ID is unknown, enter all zeros in this field. If the FinCEN CTR corrects or amends a FinCEN CTR field not present or completed on the prior filing that field must be completed by the filer if the data are known. These instructions supersede all prior instructions and guidance on electronic filing of amended or corrected FinCEN CTRs. BSA IDs are provided in acknowledgement records sent to member financial institutions by the BSA E-Filing System.
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#2177626 - 05/10/18 04:36 PM Re: Forgot to check the box Bec
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Thank you!
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