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#2250967 - 03/22/21 05:15 PM CTR Amendments
Andrew Toole Offline
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Joined: Mar 2021
Posts: 2
Hello Everyone,

I was wondering if anyone knew or could guide me on what areas on a CTR that are areas that MUST be Amended if any errors are found?

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#2250969 - 03/22/21 05:48 PM Re: CTR Amendments Andrew Toole
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 76,987
Galveston, TX
All of them?
The opinions expressed here should not be construed to be those of my employer:

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#2250970 - 03/22/21 05:54 PM Re: CTR Amendments Andrew Toole
BrianC Offline
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Joined: Nov 2004
Posts: 5,977
Only FinCEN can give dispensation to not correct an error which you would obtain by emailing the helpdesk.

There is also additional information about "Primary and secondary" errors describing when corrections of batch files are required which you can find in the Appendix T of the Exam Manual.
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!

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#2251363 - 03/29/21 01:26 PM Re: CTR Amendments Andrew Toole
GrannieTwo Offline
100 Club
Joined: Nov 2010
Posts: 180
Central IL
Our recent audit dinged us for not completing all the fields whether starred ** or not IF we knew the information. For example the NACIS code. We were not inserting the number but since we knew what the individual or the business did, we were required to complete that field. Pick your battles and sometimes it is just easier to agree and move on. Just my thoughts.
For when I am weak, then I am strong. 2Cor 12:10

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#2251368 - 03/29/21 02:09 PM Re: CTR Amendments Andrew Toole
ColoradoAML Offline
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Joined: Mar 2018
Posts: 227
Without having NAICS codes in the core or AML system, I'm not sure I would agree with that one. I don't want to dig through CDD and compare NAICS codes for every customer. If you do have the NAICS code recorded already, then I agree that it's required regardless of whether the field is critical.

If you don't have a business' ID number on file, but it's publicly available on the SOS, would they expect you to go out and get that too? These are the kinds of things that make CTRs expensive for smaller banks.

I agree with your point about picking battles though, if that one's easy enough to implement, better to just do it and have better CTRs and no questions from your examiners.

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