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#61122 - 02/13/03 05:56 PM CTR preparation - centralized?
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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I am dealing with a very manual CTR aggregation and preparation process. The final CTR is prepared online but a lot of paperwork flies around before it gets prepared by the branch the account was opened at (the "home branch").

Do most banks have the actual CTRs generated by a central area? I would like to streamline this process.
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#61123 - 02/13/03 06:12 PM Re: CTR preparation - centralized?
DeeQ Offline
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Turnpike Exit 10
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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#61124 - 02/13/03 06:17 PM Re: CTR preparation - centralized?
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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How do you handle multiple transactions at several branches for the same customer? We have this huge paper process so they can capture the aggregated transaction. It seems we could just figure that out here anyway (which we do) and complete the CTR, consulting with the branch as necessary. If neither took in or gave out more than $10,000 in one transaction, they would prepare a CTR, but we could always correct it to reflect the information for the multiple transactions. We file from here anyway.
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#61125 - 02/13/03 06:21 PM Re: CTR preparation - centralized?
DeeQ Offline
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DeeQ
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Turnpike Exit 10
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.
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#61126 - 02/13/03 09:01 PM Re: CTR preparation - centralized?
Dave M_TCA Offline
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Dave M_TCA
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Wherever my most benevolent em...
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!
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#61127 - 02/13/03 09:38 PM Re: CTR preparation - centralized?
P*Q Offline

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P*Q
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Somewhere
Our process is the same as Maria's. Branch prepares, sends to me as the BSA Officer and I ensure accuracy and mail in. Best way to do it and still catch mistakes.

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#61128 - 02/13/03 09:45 PM Re: CTR preparation - centralized?
twin1 Offline
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twin1
Joined: Feb 2003
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Gateway to the South
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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#61129 - 02/14/03 12:08 AM Re: CTR preparation - centralized?
Anonymous
Unregistered

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?
Anonymous
Unregistered

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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#61131 - 02/14/03 01:31 AM Re: CTR preparation - centralized?
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Sorry...forgot I was at home and had to sign in! That was from me. Thanks!
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Kathleen O. Blanchard, CRCM "Kaybee"
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#61132 - 02/14/03 02:00 PM Re: CTR preparation - centralized?
Anonymous
Unregistered

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?
Anonymous
Unregistered

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?
Dave M_TCA Offline
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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.
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#61135 - 02/14/03 03:32 PM Re: CTR preparation - centralized?
BrendaC Offline
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Sweet Home AL
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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#61136 - 02/14/03 03:38 PM Re: CTR preparation - centralized?
Mickey Offline
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Joined: Aug 2002
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FL
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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#61137 - 02/14/03 03:49 PM Re: CTR preparation - centralized?
Dave M_TCA Offline
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In reply to:

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.


Brenda, you're absolutely right. We had the tellers send in their log sheets whether blank or not, just to make sure that we got from everyone. And those sheets were filed with a checklist of all the tellers and calls were made if anything was missing.
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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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#61138 - 02/14/03 06:07 PM Re: CTR preparation - centralized?
cbinder63 Offline

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Colorado
We use the PACS system. Each teller/branch completes any CTRs that are required, and notify the BSA Officer (me). I review, digitally sign them and submit. Works great. Aggregations from multiple branches are caught and noted that the tellers would be unaware of this way, as well.
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#61139 - 02/14/03 06:09 PM Re: CTR preparation - centralized?
cbinder63 Offline

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Colorado
The setup for PACS is (was) a little difficult. However, once it is complete, it is worthwhile.
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