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#485558 - 01/19/06 02:02 PM CTR efiling
Cat Woman Offline
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Cat Woman
Joined: Sep 2004
Posts: 1,342
New England
Does anyone out there do this? How was the set-up process? We would want tellers in our branches to fill out the CTRs electronically, but our Audit dept would review them before being filed electronically. We have many branches and were wondering how tellers' access to this system would work. Thanks!

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#485559 - 01/19/06 02:44 PM Re: CTR efiling
CrashDavis Offline
Gold Star
Joined: Jun 2005
Posts: 283
We are beginning this process. We file CTR's centrally but all of our locations will complete the CTR. It is a great process. The CTR Co-ordinator at each of our location will complete the CTR and e-mail to the Central location and they review and send the CTR electronically.

We are going to begin this process in about two weeks.

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#485560 - 01/19/06 06:02 PM Re: CTR efiling
banker1976 Offline
Gold Star
Joined: Nov 2005
Posts: 346
Mid-Atlantic
We started the E-filing of CTR's back in August 2005. Before that time, our branches completed the CTR's then forwarded to our BSA Officer for signature, retaining a copy and then mailing. We have discontinued at the branch level for the branches filing out electronic CTR's. Our BSA Officer completes the CTR's when reviewing daily large cash reports. Once up and running with the electronic filing you can create a template of your recurring customers and provided nothing changes from transaction to transaction, the only thing you'll have to change is the date and dollar amount. Having one person handle the CTR's has also significantly reduced error notices we would receive from the DCC. We're not a big bank; we only have 10 branches so it may be different for banks with lots more branches; however the e-filing is the best thing in CTR filing!

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#485561 - 01/19/06 10:23 PM Re: CTR efiling
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
Banker1976: Does your teller or core system create the electronic CTRs or do you manually create them on the e-Filing Web site?

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#485562 - 01/20/06 02:22 PM Re: CTR efiling
banker1976 Offline
Gold Star
Joined: Nov 2005
Posts: 346
Mid-Atlantic
We have disabled the automatic creation of CTR's from the teller systems. As CTR's needed to be filed, I created a template manually for each account. Creating the template takes about 1 minute. Entering and submitting the information when needing to file a CTR is about 30 seconds. BSA E-filing is a wonderful tool and considerably less burdensome when filing CTR's.

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#485563 - 01/20/06 03:19 PM Re: CTR efiling
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Step one is to determine whether you can utilize your teller system for the preparation of CTRs. When the process is interfaced with the teller line, you have much better control over the entire process.

We batch file CTRs that are created through our teller system (JHA's Vertex). Information on existing customers is automatically pulled from our core system CIF files (they can be modified as needed for CTR preparation such as when we need to use a street address instead of a PO box). CTRs will appear automatically when the teller system knows that a customer has reached the reporting thresh hold. A CTR cannot be overridden, it must be completed. CTR records are automatically merged at the end of the day for review by BSA staff and comparison to core system cash reports. Once finalized, the CTR batches are submitted by the designated BSA staff member via BSA E-file.
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#485564 - 01/20/06 07:08 PM Re: CTR efiling
Snowgirl Offline
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Joined: Sep 2003
Posts: 714
I just recently signed our bank up for the BSA E-filing through FinCEN. My computer is somewhat old and it took some tweaking to finally get the digital signature and everything loaded, but the e-filing help was very good. They provide you with some software that you download from the internet. Our IT guy then distributed this software to all of our tellers at each of our branches as well as the blank CTR which came with the software. You can then make up templates from this blank software with customers names, addresses, bank address and information for recurring CTRs. Then all the teller has to input is the date and amount. It really helps cut down on the errors. The tellers at the branches then e-mail the form to our head office where I review them and then digitally sign them and submit them to the IRS. It is much easier than before. You can then save the form to your computer just like a Word document. We have a couple of people here in the main office that have digital signatures and all our tellers are allowed to do is complete the form. It has worked good for us. We have 11 branches - so not too big. Works good for us. Hope this helps.

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#485565 - 01/21/06 04:50 AM Re: CTR efiling
SMQ, CRCM Offline
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SMQ, CRCM
Joined: Apr 2001
Posts: 4,828
Between the lines
Isn't there an approaching date when we will all have to e-file? If so, does anyone remember the drop dead date? Thanks,
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#485566 - 01/21/06 10:36 AM Re: CTR efiling
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Several years ago there was a notice of proposed rulemaking that would have mandated magnetic media filing for CTR filers who filed more than 1,000 forms per year. It was dropped. I don't know of any recent announcements that resurrected that discussion.

Just a personal opinion, but I think it is more likely/logical that they would require SAR filing to be done electronically. There are fewer forms filed, electronic filing of SARs imposes no appreciable burden over paper filing on small institutions, there is greater urgency in getting the SAR information into the data base and the Inspector General specifically recommended it in a recent FinCEN audit.
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#485567 - 02/07/06 06:59 PM Re: CTR efiling
Cynthia1 Offline
New Poster
Joined: Sep 2005
Posts: 6
How long did it take for you to receive notice once you filed your application for magnetic media reporting? We are all set up as far as having a digital signature and the FinCEN software, just waiting for the acknowledgment to send in a disk. I've heard that takes months.

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#485568 - 02/08/06 04:46 PM Re: CTR efiling
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
It took us 2-3 months.
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