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#452455 - 11/04/05 04:14 PM bsa/aml audit
cat Offline
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Joined: May 2004
Posts: 4
During the course of an internal audit, I noticed a few ctr's that were not filled out correctly (sections A & B). Do we need to correct and refile?

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#452456 - 11/04/05 05:09 PM Re: bsa/aml audit
Dip Offline
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Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
i would say only correct them if fincen sends them back, unless the errors are major (filed or the wrong person, gave a wrong ssn--errors like not marking "multiple persons" aren't major). otherwise, make it a finding in the report and recommend increased training and better control for ctr's
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#452457 - 11/04/05 05:53 PM Re: bsa/aml audit
Ms Auditor Offline
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Joined: Oct 2001
Posts: 148
Upstate NY
I guess I'm a stickler ... I would recommend that the BSA Officer send amended CTRs. But that's just my opinion.

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#452458 - 11/04/05 07:33 PM Re: bsa/aml audit
dgp Offline
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Joined: May 2005
Posts: 145
I agree with Ms Auditor, I have always recommended filing amended reports.

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#452459 - 11/04/05 09:04 PM Re: bsa/aml audit
GregS Offline
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Joined: Jan 2005
Posts: 135
Sunny Florida
Our last go around with FDIC they recommended re-file. We use E-File and since someone else is doing FinCEN's input they would like zero errors. As they move towrds required electronic filing the tolerance for errors will be less.
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#452460 - 11/04/05 09:20 PM Re: bsa/aml audit
Anonymous
Unregistered

Re file. A good examiner will comment on this.

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#452461 - 11/04/05 09:57 PM Re: bsa/aml audit
Dip Offline
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Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
should we refile even on minor errors? i am finishing up my bsa audit and this would be good to know since it would change my final audit report
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Dabbling in banking, law, accounting...the life of a trustee.

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#452462 - 11/04/05 10:14 PM Re: bsa/aml audit
Anonymous
Unregistered

The general rule is that CTRs should be completed correctly and filed according to the instructions. There is a box for "amended." There does not appear to be any guidance, that I'm aware of, as to what type of error would require filing an amended CTR vs. what type of error would not. Therefore, I believe the safe route would be to file an amended CTR.

From the CTR instructions:

Item 1a. Amends Prior Report. If this CTR is being
filed because it amends a report filed previously, check
Item 1a. Staple a copy of the original CTR to the amended
one, complete Part III fully and only those other entries
which are being amended.

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#452463 - 11/07/05 06:15 PM Re: bsa/aml audit
Dip Offline
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Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
i meant minor as in the teller reported multiple persons in section a but did not mark the multiple persons box--REALLY minor errors like that
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#452464 - 11/08/05 07:40 PM Re: bsa/aml audit
Kansayaku Offline
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Joined: Jan 2003
Posts: 1,454
metsuretsu
I would call the DCC and ask for guidance in writing. They may tell you that for something that minor, you need not re-file.
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#452465 - 11/11/05 09:27 AM Re: bsa/aml audit
Anonymous
Unregistered

Do you have a phone number?
Thanks

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#452466 - 11/11/05 08:24 PM Re: bsa/aml audit
Kansayaku Offline
Diamond Poster
Joined: Jan 2003
Posts: 1,454
metsuretsu
Sure. 1-800-800-2877

Best of luck!
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I have many opinions; some are good, some are bad, and some don't contradict.

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#452467 - 11/14/05 02:49 PM Re: bsa/aml audit
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
I'd refile.
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#452468 - 11/20/05 10:37 PM Re: bsa/aml audit
Anonymous
Unregistered

Better get them refiled. Be careful with the entire BSA/anti-money laundering topic. The regulators are focusing hard on this topic. I speak from experience (my opinion only). Good luck.

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#452469 - 11/30/05 06:55 PM Re: bsa/aml audit
BankerKB Offline
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BankerKB
Joined: Jan 2005
Posts: 288
I would re-file on any error you find. There would be no reason I'd see where they would question you amending it but I could see them questioning you not fixing it.
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