Skip to content
BOL Conferences
Thread Options
#2254389 - 05/25/21 07:41 PM Corrected CTR
Luv2run Offline
Platinum Poster
Joined: Jan 2015
Posts: 616
I found an error on a CTR and would like to file an amended CTR. If I do so, is the corrected error still an issue in an examination?
_________________________
If at first you do succeed....try something harder
-fortune cookie

Return to Top
BSA/AML/CIP/OFAC Forum
#2254392 - 05/25/21 07:53 PM Re: Corrected CTR Luv2run
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The error happened and filing a correction doesn't undo that error, it just provides FinCEN and law enforcement the corrected information. That said, a single error would not normally result in an "issue" in an exam. A pattern of errors is likely to.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2254393 - 05/25/21 07:54 PM Re: Corrected CTR Luv2run
BrianC Online
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,717
Illinois
Examiners look much more favorably upon issues that are self-identified and self corrected. Was the error caught through your normal quality assurance processes? If it was, then that demonstrates that your quality assurance processes are working.

To show that your BSA Program is working, also document any follow-up training that was done with the employee who made the error. If this was an isolated occurrence, it most likely would not be a concern during an exam.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2254404 - 05/25/21 08:25 PM Re: Corrected CTR Luv2run
Luv2run Offline
Platinum Poster
Joined: Jan 2015
Posts: 616
Thank you both!
_________________________
If at first you do succeed....try something harder
-fortune cookie

Return to Top
#2254413 - 05/25/21 09:27 PM Re: Corrected CTR Luv2run
CI@MBOC Offline
Junior Member
Joined: Apr 2021
Posts: 42
Probably depends on the mood your regulator/examiner is in that day.

Return to Top

Moderator:  Andy_Z