This came up in a recent internal BSA audit. In reviewing the daily reports used to identify reportable transaction, the auditor noticed a case where the teller ran the "ticket" as a cash out, but no currency ever left the bank. The auditor is stating that since it was a "cash out" that a CTR should be completed. I research every transaction and can determine when actual cash is given to the customer. In this particular case, no cash over $10,000 was taken out of the bank by the customer. I do document this on the reports. CTR doesn't stand for "cash" transaction report but "currency" transaction report. No currency, no CTR. Opinions please.

Thanks!

The instructions for completion of a CTR are pretty plain -- You report actual currency transactions that meet the threshold, not bookkeeping entries. Auditors are just like the rest of us -- they need to understand the rules.

We run across this situation often due to some limitations in our teller system. We have never had a problem with our auditors or examiners so long as we can document the true nature of the transaction. I have had to print the teller transaction reports to prove what I noted on our aggregation logs, but that has always been enough. I can't understand why they would want you to file a CTR on a customer's transaction that wasn't really a cash transaction??

If the currency didn't leave your institution, you don't need to file a CTR.

On daily reports, I use to note any related transactions to show where the funds went. Our auditors never had any issues with that. As long as the flow of funds is documented and you can show that there was no currency dispersed you do not need to file.

Thanks to all for your input. I was confident in my opinion, but it never hurts to have some additional input from BOL folks.

Thanks again.