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#2256115 - 06/29/21 05:11 PM CTR Record Retention - Text Record OK?
Madawaska Offline
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Joined: Sep 2008
Posts: 105
Records are archived in a text format which is the same format the CTR Batches were filed. Internal Audit is testing for record retention compliance and all I can provide is a text record of the CTR filing. Auditor is asking for a pdf copy of the CTR. CTR was created in AML software electronically and never in the CTR pdf form. I understand the text record is hard to read, but it is our record of the filing and what was filed.

The FFIEC manual states CTRs can be retained in an electronic format. Is that all I need to communicate to the auditor?

If anyone has anything more substantial that I can provide to audit, please let me know.


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#2256117 - 06/29/21 05:27 PM Re: CTR Record Retention - Text Record OK? Madawaska
rlcarey Offline
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Joined: Jul 2001
Posts: 79,633
Galveston, TX
Auditor is asking for a pdf copy of the CTR.

Tell the auditor to pull there head out of the 1990's. They can't be much of an auditing firm if they are making those types of statements in this day and age. I quit my compliance auditing practice five years ago now and almost all of my clients where using total electronic records. They really are not that hard to read.
The opinions expressed here should not be construed to be those of my employer:

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#2256145 - 06/30/21 12:29 AM Re: CTR Record Retention - Text Record OK? Madawaska
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,068
Toano, VA
I ran into a similar challenge 30 years ago. The subject was electronic retention of adverse action notices under Reg. B, but the challenge is comparable to what your auditors may be saying about CTR filings.

My bank's credit card division (now Capital One) had a huge volume of adverse action notices, so the business unit automated the process and switched from microfilm of hard copies to electronic retention of letter segments and denial codes. The system had been used for years before we were criticized during a Fed compliance exam. The finding surprised me, but at the end of the day, I agreed with their observation that the codes we were retaining were input codes, not the processed output. There was no objection to the electronic records, only to the fact that we were not retaining copies of what was actually sent, but rather what we intended to send.

Check to be sure your records are captured from the output stream of the system that generates the CTR filings before telling the auditors to pound sand.
...gone fishing.

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