Thread Options
#357915 - 05/10/05 07:47 PM Cost of filing your next CTR?
Richard Insley Offline
Power Poster
Richard Insley
Joined: Oct 2000
Posts: 9,999
Toano, VA
Who's done a time & motion study on filing CTRs? What is the fully-loaded cost of preparing, filing, and reviewing one CTR these days? Is it more than $10?
_________________________
...gone fishing.

Return to Top
BSA/AML/CIP/OFAC Forum
#357916 - 05/10/05 08:59 PM Re: Cost of filing your next CTR?
Runin' Reb Offline
100 Club
Runin' Reb
Joined: Dec 2003
Posts: 102
West Coast
I'll take a stab and give you a quicky:

Well lets see...the average teller at our FI makes between $8.66 and $17.31 an hour....lets use $12.00 per hour as an average or .20 cents a minute.

Tellers complete the CTR using the BSA E-Filing system and email it to the Compliance Dept for review: 6-8 Min. (times are worst case scenario-could be shorter if they have pre-made templates for recurring customers, this is common when using the E-Filing system)

Tellers make copies of deposit slips, Cash in tickets, Change order Slips, etc and interbranch to Compliance: 6-8 Min. (could be shorter or longer depending on the mood of the copier)

Misc. Time: 2 min.

Total time to complete CTR, email to Compliance,Make copies and send interbranch to Compliance: 18 Minutes (worst case scenario-I've personally done it in less than 10 minutes)

18 min. X .20C and hour: = $3.60 per CTR.

We file an average of about 250 CTRs a month.
250 X $3.60 = $900 a month or $10,800 a year

These figures don't include what happens to the CTR after it gets to the Compliance Dept.

I've got a Compliance Analyst that works 25 hours a week and does nothing but review and file CTRs. $15.00 an hour or .25C a minute

The branch will email the CTR to the Analyst. She in turn will look at the CTR for accuracy. She will compare the CTR to the Agg. Report and copies of the transaction. You need all of these to determine if the CTR was completed accurately. All in all, that takes about 1-2 minutes per CTR.

Then she will save the CTR in a file for that specific day. Once all the CTRs have been accounted for on that day, she will send them one by one via the BSA-Efile System. It takes about 15 seconds to send a CTR. A few days go by, and we get confirmation from BSA E-file if the CTR is correct or an error. She saves those confirmations in the same file as the CTRs by date. Again, that takes about 15 seconds per CTR.

2 minutes for review: .25C a minute x 2 minutes = .50C
Send/receive CTR via BSA E-File: .25c a minute x 1 minute = .25c
Total= .75C a CTR.


Recap:


$3.60 from above, plus .75C = $4.35 per CTR from creation, review, submission, and confirmation.

$4.35 x 250 (monthly CTR avg) = $1,087.50 a month x 12 months = $13,050.00 a year

So my not-so-quick answer to your questions would be No, not even close to $10.00 a CTR. Not in today's environment with electronic filing. I'd say it's closer to $5.00 However, Banks still filing by paper could be an entirely different ball game.
_________________________
"Saying what we think gives us a wider conversational range than saying what we know"

Return to Top
#357917 - 05/10/05 09:05 PM Re: Cost of filing your next CTR?
Jokerman Offline
10K Club
Joined: Nov 2003
Posts: 12,846
By my analysis, you pay your compliance analyst $19,500 per year (without payroll taxes or benefits), so that equals $6.50 per CTR (3,000 per year) just for their review and filing, since that is all they do. And that is before you include your tellers or any other personnel time.

Return to Top
#357918 - 05/10/05 09:06 PM Re: Cost of filing your next CTR?
Lestie G Offline

Power Poster
Joined: May 2002
Posts: 3,605
Near the Land of Enchantment
We've also got to consider the cost of the software that we're using on these things, in addition to the cost of the paper to copy, the space to store, the manager's salary who reviews the CTR's filed, the costs associated with reporting to the Board....

And no, I don't have any bright ideas about how to measure all that! But I may give it some thought! Could be very enlightening.
_________________________
Opinions my own.

Return to Top
#357919 - 05/10/05 09:19 PM Re: Cost of filing your next CTR?
Runin' Reb Offline
100 Club
Runin' Reb
Joined: Dec 2003
Posts: 102
West Coast
Good stuff, both good points.....lestie-I wasn't even about to go there! I was focusing more on a single CTR as opposed to the total cost of BSA Compliance for a bank.
_________________________
"Saying what we think gives us a wider conversational range than saying what we know"

Return to Top
#357920 - 05/10/05 09:36 PM Re: Cost of filing your next CTR?
complianceman Offline
Platinum Poster
complianceman
Joined: Mar 2005
Posts: 687
New Albany, IN
This analysis could be different depending on the overall fixed costs and variable costs incorporated into the calculation. The fixed costs once determined would not change. But with the variable costs, depending on the number of CTR's filed, whether they are filed electronically or via mail you would need to include storage space in the server or the storage space for copied forms. Additionally, you would need to incorporate the cost of postage. That could vary as well because you could send one form in a envelope or multiple forms in an envelope. So the variables are so great that the request would have to specify the type of system, if any, the ability to file a soft copy of a hard copy, whether storage is hard copy of soft copy. I am sure there are others but I would have to say in my environment, $2.50 per CTR is reasonible.
_________________________
The opinion stated here is what it is, My Opinion.

Return to Top
#357921 - 05/10/05 10:36 PM Re: Cost of filing your next CTR?
Richard Insley Offline
Power Poster
Richard Insley
Joined: Oct 2000
Posts: 9,999
Toano, VA
Excellent analysis! We're getting there.

Jokerman touched on other compensation costs, but what about your full load factor? What factor do you use to approximate the FULL cost of employing those people who pump out the CTRs, including: payroll taxes, paid vacation, other fringe benefits, office space, equipment, telecommunications, and training? For budgetting purposes, my bank used to load the cost of each position with a factor somewhere between 1.25 and 1.50 times salary.

This is an important number and it can never be more than an estimate, but we should be able to approximate a cost range. So far we have $2.50 (complianceman) to $5.00 (Runin' Reb) to $11.50 (Jokerman's revision of Runin' Reb's estimate.)

Recently a thread covered John Byrne's bold challenge for Congress to consider repealing the CTR requirement. If this idea ignites, he will need fuel from the industry to keep it burning. The last time John got a significant CTR filing concession (the Phase I and II exemption system), he made very good use of the filing cost estimates by banks of all sizes throughout the country. It's very effective when our lobbyists can present a reasonably complete cost/benefit case to legislators.
_________________________
...gone fishing.

Return to Top
#357922 - 05/11/05 02:59 AM Re: Cost of filing your next CTR?
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
My only concern about the elimination of CTR's for "seasoned" customers is - what constitutes seasoned? And would this become another code word for "Exemptions"? If so, would banks find it easier to consider all of their customers as "not seasoned" to avoid second guessing by examiners?

And we still have the "stupid structuring" SARs which essentially gives us a system where almost ALL cash transactions either above or below $10,000 get reported in some manner or another. And the irony is that the SMALLER cash transactions get reported on a Suspicious Activity Report.

I say - eliminate CTR's all together and have the banks sumbmit a monthly aggregate cash transaction report for all accounts with total cash in or cash out exceeding $10,000. We get the report anyways, so why not let the government and law enforcement agents earn their dime by reviewing the data?

This would eliminate useless CTR's and stupid SAR's.
(No CTR's = no structuring except for multiple account structuring which IS the type of activity we SHOULD be looking for - if we had the damn time!)
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#357923 - 05/11/05 10:07 AM Re: Cost of filing your next CTR?
Richard Insley Offline
Power Poster
Richard Insley
Joined: Oct 2000
Posts: 9,999
Toano, VA
Regardless of which reform idea gets traction, John will need up-to-date cost information to make a compelling case. We're wasting time and money on low-value CTR filing that could be spent on more productive activities. By putting a dollar value on the waste, we can give Congress a good idea of how many off-budget dollars it can "spend" on beefing up the substantive aspects of our nation's AML program.
_________________________
...gone fishing.

Return to Top
#357924 - 05/11/05 11:08 AM Re: Cost of filing your next CTR?
Richard Insley Offline
Power Poster
Richard Insley
Joined: Oct 2000
Posts: 9,999
Toano, VA
If anyone's interested in getting a good CTR cost estimate for internal use (budgetting, board reports, etc.) and to share in this thread, give me your EMA and I'll send you my CTR cost estimating spreadsheet. You fill in the variables for each bank employee who touches a CTR and the SS will give you a total cost per CTR. This is a handy number to know when your directors or execs want to know the impact of BSA on your institution.
_________________________
...gone fishing.

Return to Top
#357925 - 05/11/05 01:17 PM Re: Cost of filing your next CTR?
Anonymous
Unregistered

we file almost 1,000 CTRs per month by paper and our costs without tellers but including time for monetary instruments and exemption management is about $10 per form

Return to Top

Moderator:  Andy_Z