Aggregation. I know the rules state that "if the bank has knowledge" of certain transactions that trip a CTR, then we file. And "Having knowledge" essentially means our software captures the data for the report. But does the law say if the bank is using software to capture CTRs, that the software must capture those cases when one conductor handles several different company transactions??? The only knowledge we have is that teller might put 2+2 together and notice that these five deposits to different companies is more than $10,000. What if they don't recognize it? Is the bank obligated to use their software to aggregate based on the Conductor's SSN??

If this is in a FAQ somewhere, I sure haven't seen it.

Thanks.

You have to report what you know. Are you require to develop systems to catch every possible scenario - no. If you are capturing the conductor's SSN on transactions less than $10,000, then you would know.

Thanks RL.

If examiners see that transactions are falling through the cracks when a bank isn't using features in its systems that can detect them for aggregation, a bank should expect to at least get admonished to start using the tools in their toolkits to inform their CTR filings. It can depend on what's getting missed (missing routine "pocket-money" ATM withdrawals isn't usually a big deal, but missing a conductor making three $5000 cash deposits to three separate businesses in the same teller visit is a really big deal) and the cost of beefing up training and/or systems to eliminate those cracks.