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#2262338 - 11/10/21 02:54 PM Unnecessary CTR Filed
TheManofSteel Offline
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TheManofSteel
Joined: Nov 2006
Posts: 10,068
Fortress of Solitude
A bank files a CTR that it later learns it should not have filed, due to aggregating transactions that should not have been part of the tally. Can this be amended? Can the CTR be rescinded? Or is this the type of issue that the bank should be contacting FinCEN about directly?
Last edited by TheManofSteel; 11/10/21 02:55 PM.
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#2262349 - 11/10/21 03:30 PM Re: Unnecessary CTR Filed TheManofSteel
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,722
Illinois
There are no takebacks for CTRs. All you can do is note how the error was identified, and procedure/process changes that were implemented to keep it from happening again and any training that you provided to staff.

The only process FinCEN has for CTRs filed in error is to surpress duplicate CTRs.
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#2262351 - 11/10/21 03:41 PM Re: Unnecessary CTR Filed BrianC
TheManofSteel Offline
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TheManofSteel
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Posts: 10,068
Fortress of Solitude
Thank you. As we never came across this one previously, I was unsure how to proceed.
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#2262356 - 11/10/21 04:26 PM Re: Unnecessary CTR Filed TheManofSteel
John Burnett Offline
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John Burnett
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Cape Cod
If this had been a case in which, after carving out the transactions that should not have been included, there was still enough to report, you would have needed to file a corrected CTR. But, as Brian reported, you can't just wipe out the filed CTR completely.
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