I've been processing CTRs for years and technology is making me think too hard. We have new ATMs that can identify cash deposits, our BSA/AML software shows the transactions as occurring on the actual date of deposit as opposed to our core which shows it as the posting date. Our software does not generate a CTR since the deposits occurred on 2 different dates but our core reports show a CTR is needed, therefore we have to do them manually. Aside from the suspicious activity, do we still go by posting date even though we know the physical dates are different?

IMO, I would think it would be the actual date the transaction occurred.

Unless FinCEN has issued instructions to the contrary (I've been retired 10 years), any transaction date(s) you report should match the bank's accounting records. If you didn't, it would be difficult (if not impossible) to respond to LE requests for additional information months after the fact.

I would agree that it is the actual date of the transaction. I would note on the Core reports as such and not file CTR, assuming you reconcile the BSA with Core to make final determination as to what gets filed.