I was reviewing some CTRs filed by my new back-up (who is still in training) and found an issue on an amended CTR.

We had 2 CTRs filed on the same day (CTR A and CTR B). CTR A had an error, and I directed the back-up to file an amendment to correct it. He filed the amendment, but when I reviewed the file I noticed that the acknowledgments for the original CTRs A & B had gotten mixed up and mislabeled. Meaning he had used the BSA ID number for CTR B on the amendment for CTR A. I'm not sure how to correct this. I've called FinCEN twice with no return phone calls.

I have everything documented about the issue in my files, and have already addressed and implemented a new process for my back-up to follow so this doesn't happen again. But what do I do about the amendment error? Do I amend the amendment? Do I amend the original CTR A again using the correct BSA ID number? Do I need to do anything to CTR B since the BSA ID for CTR B was referenced on the amendment for CTR A?

You will probably need to amend the amendment and then file a corrected amendment to CTR A. But before you do anything, I suggest you contact FinCEN to ensure you don't end up shooting yourself in the foot trying to correct this mess.

Thank you. I've called the help line twice in the last 3 days with no response. Hoping they call me back.

Updating in case anyone else runs into this scenario....

FinCEN finally called me back. I had to file 2 new amendments as follows:

Amend CTR A and reference the original BSA ID number for CTR A. By referencing the incorrect BSA ID number on our first amendment, we never actually touched CTR A.

Amend CTR B but reference the BSA ID number from the erroneous amendment. The first amendment filed in error by using the BSA ID number from original CTR B replaced CTR B in the system. Because I save all of my filings, I opened my original CTR B pdf, unchecked initial filing, checked Amend Report, and listed the BSA ID number from the first amendment. Per the lady at FinCEN, that "reset" my CTR B with the original information.