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#2137813 - 07/12/17 08:41 PM CTRs and Rounding
Nick Offline
New Poster
Joined: Mar 2017
Posts: 20
Hello all,

We have a situation where two separate business (different EINs and account numbers) had multiple cash deposits with the same transactor. When filing the CTR, we will need 3 different Part I. One for each of the two business and one for the transactor. When aggregating the transactions there are some that did not have an even dollar amount, so I know that we have to round the total. When we round business 1 we have a total of 12,963.00. When we round business 2 we get a total of 216.00. Rounded amounts for the businesses equal 13,179. Now.... the unrounded amounts total $12,962.26 for business 1 and 215.66 for business 2. When they are aggregated and rounded they total 13,178.00 My questions is, do we add the two amounts are in part I for the two business and use that number for part I for the transactor (13,179)? Or do we use the total amount of all the transactions - 13,178. What amount should we use for part II section 25? Sorry for the wordy post. Thanks in advance!

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#2137817 - 07/12/17 08:50 PM Re: CTRs and Rounding Nick
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
Welcome to BOL.

FinCEN CTR FAQ #28 states that either method is acceptable.

28. When we round the amounts on the FinCEN CTR, the total in Item 25/27 may differ from that in Item 21/22 due to rounding. Is this acceptable??

Yes, this is acceptable, if the difference was a result of a financial institution following the instructions on rounding dollar amounts. The following scenario outlines the two choices available for the filing institution to follow in completing Items 21/22 and Items 25/27:

Scenario: A customer deposits $8,345.18 into his or her personal account and also makes a loan payment of $2,345.43 in the same business day. The daily report shows this customer brought in $10,690.61 in one business day.
•Option 1: Per the FinCEN CTR instructions, each dollar amount reported on the FinCEN CTR is to be rounded-up to the next dollar. Therefore, the financial institution would enter $10,691 in Part I Item 21 of the FinCEN CTR. In Part II, the financial institution would enter $8,346 in Item 25a and $2,346 in Item 25b. As a result, the total in Item 25 would reflect $10,692. The FinCEN CTR will validate and be accepted as the total in Item 21 (or Item 22 for a cash-out transaction) is not more than the total for Item 25 (or Item 27 for a cash-out transaction). Filers can internally document as a general note to their FinCEN CTR files that the amounts may differ in these situations as a result of following the FinCEN CTR rounding instructions. Both regulators and law enforcement were involved in the designing of the FinCEN CTR, and are aware and accepting of the possible discrepancy.
•• Option 2: As a means of avoiding these differences on the FinCEN CTR, the filer can round up all the amounts involved separately and then aggregate the separately rounded amounts. For example, using the above scenario, the filer would round-up the $8,345.18 and $2,345.43 transactions separately, to $8,346 and $2,346, respectively, which would aggregate to $10,692 and then enter this amount in Part I Item 21 of the FinCEN CTR. In Part II, the financial institution would enter $8,346 in Item 25a and $2,346 in Item 25b. As a result, the total in Item 25 would reflect $10,692 and Items 21 and 25 would match. If applicable, a financial institution should still internally document as a general note to its FinCEN CTR files if these amounts differ slightly from the amounts shown on the daily reports due to rounding the amounts involved separately.
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