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#2260333 - 09/28/21 03:26 PM Newly released CTR form - discrete filing
J_G Offline
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Joined: Dec 2010
Posts: 261
I just noticed a new CTR form was released in June of this year (version 1.3). We are a discrete filer. Do I need to do amendments for the CTRs done with the previous form that was used before this newer version came out? I don't really see any differences.

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#2260335 - 09/28/21 03:41 PM Re: Newly released CTR form - discrete filing J_G
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
Since the invent of required electronic filing - what form?
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#2260407 - 09/29/21 02:26 PM Re: Newly released CTR form - discrete filing J_G
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
It's likely that the "form" is identical to version 1.2 except for some updated instructions (the comments that appear when hovering over a field).
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#2260408 - 09/29/21 02:26 PM Re: Newly released CTR form - discrete filing J_G
ColoradoAML Offline
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Joined: Mar 2018
Posts: 343
I would recommend calling FinCEN and asking them and keeping a record of their response. I doubt you'd have to amend the reports but a call would probably help you avoid arguing about it with an auditor or examiner that felt differently.

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#2260411 - 09/29/21 02:35 PM Re: Newly released CTR form - discrete filing J_G
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The change is likely part of FinCEN's modernization of the private side of the filing system, which was activated in June.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#2260426 - 09/29/21 03:53 PM Re: Newly released CTR form - discrete filing J_G
Amy S Offline
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Joined: Sep 2020
Posts: 224
The form itself is the same. What I have saved prior to the change in the website and current form both show "Version Number 1.3". I downloaded & saved the "new" form just to be safe.

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#2260444 - 09/29/21 05:54 PM Re: Newly released CTR form - discrete filing J_G
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I download version 1.3 three years ago (when it was easily found on the site, outside the private filing portal).
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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