I process all the CTR's for my bank, which involves 160 branches located in 4 states. We process about 500 CTR's in a month and that is with a very aggressive exempt list. At the bottom of the CTR form I sign as officer for the bank and include my address which is the main operation center, so that if their is an error on the form notification comes back to me. I have been doing this for ever since we started the process (over 5 years). An internal auditor wants the address of where the transaction took place, in some case that can be several branches. What is a girl to do...I of course have internal documentation which is kept with that days batch of CTRs on where each transaction occured..

My initial thought is that the process of CTR completion needs to be delegated to branch level. Review of the CTR can still flow through a single source prior to release to FINCen. A simple and effective way to accomplish this would be to use the Patriot Act Communications System (PACS) from FINCen.

The majority of the transactions involve multiple occurances with different branches.. The tellers really don't have knowledge of the other transaction.

Explain to the auditor, that in many cases the filings were the result of aggregated transactions involving more than one location. The auditor should be able to look up the information to see where each portion of each transaction took place if necessary. If you have that information available, provide a copy to the auditor for their review.

As an auditor, I look at this type of information every time I audit BSA. In many cases the location is unimportant, but at times it can be very important.

From the instructions to the CTR:

"Items 38, 40, 41, and 42. Address.—Enter the street address, city, state, and ZIP code of the financial institution where the transaction occurred. If there are multiple transactions, provide information on the office or branch where any one of the transactions has occurred."

Any accurate address will work, but you cannot default to the main address if none of the transactions took place there.

If you file electronically, even though the branch addresses will be listed, the electronic problem reports will come back to "central."

John, given her volume, let's hope she files electronically. However, what do you mean by "central?" Is that the address the bank stipulates when it fills out the application for electronic filing?"

Well, we do not file electronically,, me are moving toward that...Do you think I would have to file a corrected version on my prior CTR's...

Given your branch network and current level of CTs you really need to look into total CTR automation, including mag filing. Very likely, you are not 100% comfortable with some of those "aggressive" exemptions, too. By reducing filing costs through automation, you should be able to take a more conservative stance and still save time and money.

Actually I am comfortable with the exemptions,, majority are publicly traded and the others have been a customer over 3 years, but I agree we are in need of electronically filing.. can any one refer me to a vendor/source that they are using..

As for a vendor, you may not need one. Start your investigation with the PACS program: http://pacs.treas.gov/index.jsp

As to filing corrections on several thousand CTR's because of an error in the address, I feel very comfortable saying FinCEN would say "not necessary." However, my saying it does not get you where you want to go. Call FinCEN's friendly 800 number (800.800.2877) and "endeavor to perservere" until you get to a human being. You want to know who you can write to there that can give you dispensation from filing corrections and what kind of information they need. (They have a standard form to complete for omitted CTRs, but it doesn't really fit your fact situation.)

P.S. Thank your auditor.

yeah,, I'll thank him Also,, of course no examiner every said anything either,, they look at it every year,,

Tell the auditor that you file CTR's for aggregate transactions. It's a control to ensure that they are done. This is not a violation.