Good morning. My institution has just incorporated a consumer loan subsidiary. Is it necessary to exempt this subsidiary individually from CTR filings?

I work at a large financial institution. We do not file CTRs on aggregated transactions involving our subsiaries (consumer loan, insurance, mortgage providers) nor have we filed an exemption regarding them. Our regulators have never mentioned anything about it (thank goodness if we're wrong). Does anyone file CTRs or exemptions regarding their subsidiaries. When a single transaction in currency is involved, we do file regarding the individual who cashes the loan disembursement check or tries to repay an obligation with cash. I'd love to know what other people are doing.

I investigated with FinCEN through the helpline. I was informed that the corporate structure is the key. I was told that aggregated transactions by bank subsidiaries are not reportable if the subsidiary is listed on the bank's call report. (Any individual transactions that surpass the reporting threshold do need to be reported). If the bank is a subsidiary of a holding company and the other entities are also subsidiaries of the holding company, not the bank, CTRs may need to be filed regarding aggregated transactions. The person on the helpline called this type of relationship one of affiliates of the holding company rather than subsidiaries of the bank. The helpline person also stated that should the relationship be that of affiliates of the holding company, he would need to consult further on the the need to file CTRs.