Thread Options Tools
#53410 - 01/10/03 02:12 PM CTR Errors & Examiners
Anonymous
Unregistered

Has anyone been written up before from an examiner regarding the % of errors on your CTR's? I didn't know that error ratio was important, but apparently this examiner did!!!!

Return to Top
General Discussion
#53411 - 01/10/03 02:17 PM Re: CTR Errors & Examiners
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,963
TN
I did have comments made one year about the number that had been returned.
_________________________
My Opinions Only

Return to Top
#53412 - 01/10/03 03:31 PM Re: CTR Errors & Examiners
Anonymous
Unregistered

I have been told it is VERY important that we fill the CTR's out correctly. They do watch if you have had any returned because they have not been filled out right.

Return to Top
#53413 - 01/10/03 04:16 PM Re: CTR Errors & Examiners
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,630
Cape Cod
We've had that experience from auditors, but not examiners. IMHO, examiners should be looking at the overall BSA program with a focus on AML and controls. The minutia of whether box 32 is checked on a CTR should never see the light of day.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#53414 - 01/10/03 04:19 PM Re: CTR Errors & Examiners
Anonymous
Unregistered

They commented on the percentage of our total submitted that have been returned. He said that our overall % is extremely high (14%). I asked him what industry standard was (as he looked dumbfounded and said 5%). Ok, they can leave now!!!!!

Return to Top
#53415 - 01/10/03 04:26 PM Re: CTR Errors & Examiners
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,630
Cape Cod
5% seems to be the de facto standard for all sorts of error ratios for examiners. But 14% return rate does seem a little high. I trust you have analyzed these rejects to determine what, if any, patterns exist, and taken corrective action (i.e., retraining) (or plan to) to resolve the issues?
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#53416 - 01/10/03 04:43 PM Re: CTR Errors & Examiners
Anonymous
Unregistered

To be honest, I didn't know that I was "graded" on this. If I had known, I would have addressed it with training. Most of the errors are TIN issues. Going forward, there is more that I can do, it's an easy fix to reduce the return rate, but I was blindsided with this b/c I thought I was taking care of it. Thanks for your input.

Return to Top
#53417 - 01/10/03 05:40 PM Re: CTR Errors & Examiners
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
By TIN issues, I trust you are implying a TIN/Name mismatch in the FinCEN database. If that is the case, these errors are beyond your control. You are not required to authenticate every TIN you are given, just to report the information that you collect. It may be worth your whiel to factor these types of returns out and come up with your own return percentage that accurately reflects bank error rates. Then use those numbers in your response.

Return to Top
#53418 - 01/10/03 05:55 PM Re: CTR Errors & Examiners
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
This is the first time I've heard of any reviewer citing a percentage, including the concept that there is a marker for of what might be an acceptable error rate. (The IRS does have one for information returns.) It sounds as if it's an attempt at objectivity, but it could be easily distorted. I too think a 14% error rate is high, but my next question would be "What exactly was wrong?"

A lot of CTRs get kicked back becasue the name/TIN combination doesn't match. If you used the number the person gave you, it might well be wrong, but there's no way I'd let it pass in conversation that it was an error. You are not required to verify TINs and, even if you were, your ability to do so is conjectural - it has no business in the calculation or the criticism.

Expect that the agency will make its own criticims under the "program" regs. It's going to be hard to say that your internal controls or training on forms completion are adequate.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#53419 - 01/10/03 07:24 PM Re: CTR Errors & Examiners
Anonymous
Unregistered

I think that's why he looked surprised when I asked him what was the "standard" percentage of error. Many of the errors are EXACTLY Name/SS# mismatch. That let me to think that in many cases where he indicated it was a quality control issue, I could verify the name/tin to the system when I receive a CTR, and at least that way I could ensure that that information on the CTR is correct.

Return to Top
#53420 - 01/10/03 07:40 PM Re: CTR Errors & Examiners
Comply 101 Offline
Platinum Poster
Comply 101
Joined: Jul 2001
Posts: 708
Something I always look for that can get out of hand-Social security numbers from our customers that are wrong. Mismatch due to our error, perhaps a number transposed. This could be what the examiners were looking for. Errors that WE could have prevented.

These are my opinions and not those of my employer
_________________________
CRCM CAMs

Return to Top
#53421 - 01/10/03 09:20 PM Re: CTR Errors & Examiners
Anonymous
Unregistered

When I look think back on the letters I get, I know we the TIN/name mismatch ones mostly, but I can also recall the ones where they said we didn't list the birth date, but there it was right on the CTR to begin with and the ones they send me asking for a DOB on a business.

I always keep copies of the letters, documentation we gathered and our response, but am I also now supposed to keep a list so I know my percentage of errors/letters to the number of CTRs we file?

Return to Top
#53422 - 01/12/03 10:21 PM Re: CTR Errors & Examiners
Ross A Offline
New Poster
Ross A
Joined: Dec 2002
Posts: 20
What agency sent this examiner to you? Has anyone else examined by this agency seen anything like this?
_________________________
The opinions expressed here are my own and may not represent the views of my employer.

Return to Top
#53423 - 01/13/03 02:42 AM Re: CTR Errors & Examiners
Anonymous
Unregistered

We had a BSA exam in 2001 by the FDIC. They never asked to see our error returns and I never volunteered.

Return to Top
#53424 - 01/13/03 12:33 PM Re: CTR Errors & Examiners
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,963
TN
From an exam I went through a few years ago - they already know how many were returned with errors.
_________________________
My Opinions Only

Return to Top
#53425 - 01/13/03 01:51 PM Re: CTR Errors & Examiners
Anonymous
Unregistered

The agency was the FDIC. It was during a safety and soundness exam. When he made the comment, I asked when he saw the most errors (the reason I asked is because he looked at the last year and a half) and I'm fairly new here, he had exact numbers by month...so he REALLY looked at it. I guess I'm trying to think of what type of response I could give. I thought I was doing the right thing by reviewing them for completeness and then submitting them...I guess I have to double check the teller AND the person who signed off on the CTR!!!!

Return to Top
#53426 - 01/13/03 02:37 PM Re: CTR Errors & Examiners
AnonRegulator Offline
Gold Star
AnonRegulator
Joined: Mar 2002
Posts: 451
Everywhere, USA
I'd be interested to know what "written up" means here. Does that mean a violation was cited? Or does it mean there was some other comment in the report of examination recommending the bank correct some weaknesses in the BSA program, including accuracy of CTRs? The difference may seem subtle, but the ramifications may be very different.

If "written up" means just a comment in the report, the examiners are giving you a warning to to improve your BSA program, otherwise a violation may be appropriate in the future. And if they cite certain violations regarding your BSA program, they are obligated by law to impose a cease & desist order on the bank. Contrary to what you might think, examiners don't enjoy presenting banks with C&Ds. In fact, we don't particularly like laws that dictate when to use such actions as they don't always make sense in each and every situation. So we save such violations for really egregious cases and try to be proactive with banks in an attempt to avoid such situations at all. I think this is consistent with Mr. Burnett's big picture advice.

As for the percentage thing, I haven't heard of that either, although it doesn't surprise me that examiners try to quantify EVERYTHING. One reason we do that is that when we discuss an issue with bankers, the first question is, "How many times did you come across this?" So it kind of works both ways. There is no advertised industry standard or even an examinerdom threshold that I know of. I think they are just using their judgment in an attempt to get your attention and avoid potential C&Ds. AR.

Return to Top
#53427 - 01/13/03 02:56 PM Re: CTR Errors & Examiners
Anonymous
Unregistered

AnonRegulator, thank you for your response. I think you might be correct in that they are citing a weakness in our BSA program, they never mentioned a C&D (to me anyway). I don't think it's that extreme. I may have taken this comment to heart b/c I'm the one who reviews them before they leave the bank. I guess I'll have to wait and see how it's presented in write-up and then I'll know what needs to be done in order to proceed.

Return to Top