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#361675 - 05/19/05 09:53 PM Catching Multiple Transactions
bgehres Offline
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I think I remember reading somewhere that its not a violation if you fail to file a CTR because you didn't have knowledge of multiple transactions. Does anyone know if this is spelled out somewhere?

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#361676 - 05/20/05 05:51 AM Re: Catching Multiple Transactions
Andy_Z Offline
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Look at (c)(2). This is a "if you have knowledge" section. Aggregation isn't required but I couldn't imagine not having that capability.
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#361677 - 05/20/05 10:07 AM Re: Catching Multiple Transactions
Elwood P. Dowd Offline
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Andy's given you the correct language, but I'm not certain your question was about whether or not you need a system. If it was, here's some background.

Several years ago, Treasury issued a notice of proposed rule making that would have required banks to have a system for aggregating transactions. The idea was dropped because the regulation was adjudged as being impossible to write - there was no way to set a standard that would fit Mega Bank and Crossroads Bank at the same time.

However, later a nugget was added to the FDIC's examination procedures that inquired about how a bank conducted its independent BSA examination if it did not have an aggregation system. How would any reviewer know if required CTRs were filed if there were no way to reasonably locate the transactions?

The same question can readily be asked today. An aggregation system, even one that only works at the individual account level, is a practical, not a legal necessity for an effective independent examination.

If your question was along the lines of: "We did not report an instance where multiple transactions took place because there was no employee or system that was aware of them at the time. However, we found it later. Are we in trouble?" The answer to that would be a simple, "No, but you file the CTR when you discover that the multiple transactions took place and attach a memo to the file copy explaining the circumstances."

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#361678 - 05/20/05 01:44 PM Re: Catching Multiple Transactions
Kathleen O. Blanchard Offline

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It is becoming increasingly difficult to justify non-aggregation of cash for CTRs. The lack of that capability would also impact your ability to look for suspicious activity. How do you know if a customer is making multiple deposits below the threshold at several branches?
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#361679 - 05/20/05 04:52 PM Re: Catching Multiple Transactions
Reg Wrecker Offline
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Kentucky
Our current core provider does not have this function which, needless to say, is a big sticking point for me as to why we are still with them (I have many other issues too but don't write the checks so I can't just leave them). We have a manual process in place whereby employees write down all cash transactions in excess of $2500 conducted daily. Lists are faxed daily to another employee who manually checks to see if there are aggregated transactions. Archaeic but it works for the time being.
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#361680 - 05/20/05 05:02 PM Re: Catching Multiple Transactions
Kathleen O. Blanchard Offline

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We used to do that until the OCC said get a grip.
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#361681 - 05/20/05 05:03 PM Re: Catching Multiple Transactions
Chiquita Banana Offline
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Ouch QTip...that blows!

Here's a thought and kind of how our report works. We review all teller cash transactions over a certain dollar amount. Then, we review the transactions that made up the teller cash transaction. This way we spot trends during the day. Any cash transaction that a customer completes over a certain amount is logged into an excel spreadsheet so that we can review trends over time.

Just a thought. I'm surprised that your core processor can't even write a report like this. Yikes!
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#361682 - 05/20/05 05:08 PM Re: Catching Multiple Transactions
Reg Wrecker Offline
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Kentucky
They say they are working on it. In addition to something simple like this, they have no area for a passcode or mother's maiden name, DL information, risk rating at either the deposit account level or the CIF level, no where (other than as a comment) to list the number of signers required on the account. Too many things for me which keep us having to do too many manual things.

Their version of a large transaction report lumps paper with currency so when I look at that report, I have a pretty good idea of what customers generally have cash involved, but it doesn't separate it.
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#361683 - 05/20/05 05:30 PM Re: Catching Multiple Transactions
dare2dream Offline
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Wow Qtip - that horrid that your core system can't track that. Is there any light at the end of the tunnel that you might be able to change core systems, it may be a way to justify your bank doing this. I'm not sure what the fine violation would be, but maybe it could add to the justificaiton process.
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#361684 - 05/20/05 05:34 PM Re: Catching Multiple Transactions
Nanwa Offline
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Qtip, we used that same manual system when we converted to a new computer system, because we were not sure how it did aggregation between branches. We kept it up until the BSA person was satisfied with the new system and it's reports. Archaic yes, but effective!

Sometimes it doesn't hurt to occasionally look back at the old ways. It can help in explaining accounting basics.
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#361685 - 05/20/05 06:18 PM Re: Catching Multiple Transactions
bgehres Offline
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We have no way of generating a report for aggregating transactions. The way we are doing it now is filling out an internal form similar to the CTR for every transaction over $3,000 in cash. Someone then reviews these forms and fills out the CTRs when needed. We're looking for a better way!

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#361686 - 05/20/05 06:28 PM Re: Catching Multiple Transactions
Reg Wrecker Offline
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It may sound bad, but I'm hoping that issue is brought to light during our next BSA exam. Maybe not monetarily but scrutinized enough that the chief check writer will give the OK to change. There are too many other issues with the core to mention that are not compliance related but still give us fits none the less. Maybe one day my dreams will come true!
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#361687 - 05/20/05 06:35 PM Re: Catching Multiple Transactions
dare2dream Offline
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It doesn't sound bad... I completely understand. Sometimes, we can yell, holler, scream, even be on the verge of tears trying to explain what the requirements are and that we need tools to help us become compliant.

But once the examiners come in.... it becomes crystal clear to what is important.

Good luck!
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#361688 - 05/20/05 07:44 PM Re: Catching Multiple Transactions
Kathleen O. Blanchard Offline

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We had to automate when it became obvious to regulators that we had no way to find suspicious cash activity that was occurring across branches same day - that overweighed the CTR issue.
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#361689 - 05/20/05 08:23 PM Re: Catching Multiple Transactions
Anonymous
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Are you able to query your customer data base? Before we got our new system that has AML reports - our old system was able to be queried and I built reports from that.

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#361690 - 05/20/05 08:58 PM Re: Catching Multiple Transactions
Dolly Nugent Offline
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Many of us have aggregation systems for our customer's accounts. Some aggregate by TIN, others by account and others even by relationship or portfolio.

Keep in mind that many systems cannot aggregate cash paid checks drawn on other institutions. You still need to make sure your employees are alert to customers cashing multiptle checks when they are not drawn on your bank.
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