We have recently purchased a software program designed to automate the process of CTR reporting. The vendor proports to us that, if a transaction greater than $10,000 in cash is deposited into more than one account (all with the same tax ID number), it will be reported on a CTR however only the first deposit account number will appear on line 35 of the report. The vendor tells me that they have never encountered a problem with this method. However, the CTR instructions clearly state that we are to include all affected accounts. Are we still in compliance if we simply report the first account affected?

I would tell the vendor to fix their software. The instructions are pretty clear that you should report all account numbers affected by the transaction(s). I could see myself catching it from our compliance officer, auditors, and examiners on this one if it were me.

I agree with Thomas, if a regulation is clear it does not matter what problems your bank or the vendor are having complying. Reg is as reg does (to borrow from Forest Gump)
I would definitely find it unacceptable to live with this sort of problem from a vendor.

I own a software company, and I'm a former FRB Examiner. I guarantee you that all affected account numbers are to be shown, along with information as to the account owners and the transactors.

If your vendor can't fix the problem, I'd be glad to show you our system.

Regards,
Wayne Barnett, President
Wayne Barnett Software
877-945-4344

Good for you Wayne! I HATE it when a vendor tries to tell ME that a regulatory requirement doesn't matter, or that no one has ever had a problem with it. My analogy is "I can drive 80 on the freeway and not necessarily get a ticket. Doesn't mean that driving 80 is LEGAL, or that I will NEVER get a ticket!"