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#61123 - 02/13/03 06:12 PM
Re: CTR preparation - centralized?
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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I don't really know if this is any better than what you already do, but here it goes: The branch conducting the transaction completes the CTR, because they are in the position to obtain the proper ID. After completion, they get sent, either Fedex or Interoffice to our Security/BSA officer. He reviews, signs off and mails to IRS. Good luck.
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Get your facts first, then you can distort them as you please. - Mark Twain
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#61125 - 02/13/03 06:21 PM
Re: CTR preparation - centralized?
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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Sorry, Multiple transactions are aggregated on a report checked by someone in our accounting area, believe it or not. After they complete those CTRs the same procedure to the BSA/security officer.
Like I said, I don't know if this is better or worse, but I do believe that it's good to have multiple txn CTRs completed by someone other than in the branches, you never know if someone's helping someone to structure txns.
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain
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#61126 - 02/13/03 09:01 PM
Re: CTR preparation - centralized?
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Platinum Poster
Joined: Oct 2000
Posts: 686
Wherever my most benevolent em...
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We used to have a manual process much as you describe years ago (thank goodness it's automated now!). I had 25 branches that submitted a form with the basic info on it to a central location for all transactions $3000 and over. That person put the info into Excel (Qpro back then & no email or way to transfer) and different sorts were performed (SSN/Acct #/Name/Business Name) to ensure that nothing was missed. If a teller had a CTR for someone that we didn't have a template for, they filled it out with the customer info and all CTR's were filed centrally. Typically CTR's may have been needed only for established customers and if they weren't exempt (we had some exemptions back then) a template CTR was filed. By 'template' the form was pre-filled in with all the beneficiary information and possibly conductor info as well, we put in the date, $$, and whatever else was necessary and off it went.
Very labor intensive, took a few people to do it. Thank goodness for our new teller system that does all that for us!
_________________________
David J Mulkerin, CRCM All opinions expressed are mine and not those of my employer and are not to be taken as legal advice.
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#61128 - 02/13/03 09:45 PM
Re: CTR preparation - centralized?
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100 Club
Joined: Feb 2003
Posts: 111
Gateway to the South
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We are a smaller institutions where CTR preparation is still manual.
We have 4 branches. Each branch has a large currency log. Every Monday, the designated individual will look over the prior week for multiple transactions and prepare CTR's as necessary.
Eventually, I receive from each branch, all prepared CTR's and logs where I compare all branches for multiple transacitons. That way I can check the accurancy of the prepared CTR's before sending, as well as amending totals, if needed, for multiple transactions.
I hope that helps.
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My opinions belong to only three people...me, myself, and I.
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#61129 - 02/14/03 12:08 AM
Re: CTR preparation - centralized?
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Anonymous
Unregistered
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We have 32 branches and we prepare multiple transaction CTRs in the Compliance Department. The branches are responsible for filing CTRs for transactions conducted by an individual when the amount exceeds $10,000. They are also trained to file a report for multiple transactions that they have knowledge of in order to obtain the information for Section B. All the reports are reviewed in the Compliance Department before mailing. We will be going to mag filing this year.
This has worked well for our bank.
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#61130 - 02/14/03 01:28 AM
Re: CTR preparation - centralized?
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Anonymous
Unregistered
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This all confirms my decision to centralize this and end the paper nonsense. My plan is to have the branches prepare those for >$10,000 and when they have knowledge of a multiple transaction in their branch. Multiple branch transactions will be prepared in compliance and all will be reviewed in compliance. I couldn't believe it when I saw what the process was. Thanks for the info.
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#61132 - 02/14/03 02:00 PM
Re: CTR preparation - centralized?
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Anonymous
Unregistered
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David Mulkerin what type of teller system do you have. company name, etc
please
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#61133 - 02/14/03 02:30 PM
Re: CTR preparation - centralized?
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Anonymous
Unregistered
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Is anyone using the PACS system for filing CTRs? If so, how is it working? I'm in the process of setting it up here.
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#61134 - 02/14/03 03:22 PM
Re: CTR preparation - centralized?
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Platinum Poster
Joined: Oct 2000
Posts: 686
Wherever my most benevolent em...
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Anon, we are using Easy Systems EZTeller 32 (which is now part of Harland). It has a few quirks, but on the whole, it's a lot easier than paper.
_________________________
David J Mulkerin, CRCM All opinions expressed are mine and not those of my employer and are not to be taken as legal advice.
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#61135 - 02/14/03 03:32 PM
Re: CTR preparation - centralized?
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Power Poster
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
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We are in the process of setting up with PACS as well. We'll see!
One note of caution for those banks totally centralizing the CTR process. We, too, file CTRs centrally. However, it is very important to know each day whether each branch has identified CTR reportable transactions which may never be detected by a teller system or aggregation report. For example, let's say your teller observes me making a $6,000 cash deposit to my account and then coming in an hour later and making a $6,000 cash deposit to my dad's account. Those transactions will not be captured automatically; however, you have a CTR reportable situation because you have knowledge. Do you have a procedure in place to know that the office will be completing a CTR? If you don't have some type of notification procedure in place, you could be setting yourself up for a failure to file situation. (Branch says they sent the report, you never got it, so it never was filed.)
We have been transitioning to an online teller system, but I have not been able to do away with the daily branch reports that identifies each CTR prepared by the bank for the day. Tellers still sometimes prepare the CTR manually rather than key it to the teller system.
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Life without Jesus is like an unsharpened pencil - it has no point.
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#61136 - 02/14/03 03:38 PM
Re: CTR preparation - centralized?
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100 Club
Joined: Aug 2002
Posts: 167
FL
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We are fortunate that our teller system, Jack Henry Vertex, automatically prepares the reports during nightly processing and spits them out. They track all transcations for customers and after they reach $10000.01 a screen will automatically pop up as the teller is completing her transaction and they must complete the identification and employment field. Then at night the reports are automatically generated and reviewed and sent by our BSA officer.
It also tracks those transactions that are not strictly cash deposits and withdrawals ( ex. Money order purchase, Traveler check purchase, etc.). If these total $3,500 then again a screen would pop up at the teller station. We then get a monthly report for those customers that had monetary instrument purchases $3,500 or more on one day.
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