CTR Processing

Me again - - I would like to get the thoughts of anyone who wants to comment on how you are processing your CTRs, the pros and cons, etc. We used to be discrete paper filers until January of this year, when we became discrete electronic filers via the BSA eFiling system. The way our process works is that the branches complete the CTRs and then forward/mail to us in Compliance (we are in the back office), we in turn review them (again) for accuracy and correctness and then we submit them. We are looking at how to make this process easier by eliminating the branches having to physically forward the CTRs to us. I just want to get a feel for what others are doing in this area.

We do it the same way. However, and just thinking aloud, since I'm not current on the capabilities, I wonder if BSA efiling currently offers us the capability of having someone enter a CTR, but not be able to submit it. This way, they could do everything on efile to record the CTR, but then have someone in head office review and submit. If efile does not currently offer this, it might be worth submitting as an enhancement.

Rather than physically sending the CTR, some banks use their intranet to send required information. You can't really do it centrally without knowing who conducted the specific transaction(s).

I'm interested in the responses to this. We are looking at migrating to e-file within the next month or two and we've been discussing how to set up the process.

The tellers save the CTR to a folder on their computer that I have access to from my computer. When the teller has completed the CTR they IM their supervisor who also goes to the folder and verifies the CTR for accuracy. The supervisor will IM me once she verifies the CTR and I go to the folder and review the CTR and submit it.

Our e-filing is also set up on a shared drive, so that an authorized person at each branch can go in and 'build' the CTR, but they are not authorized to submit. Branches e-mail the BSA at the Main Office when their file is complete - no paper CTR copies. CTRs are reviewed on-line by BSA - branches are advised of any needed corrections; submission is done weekly from the Main Office only.

Branches can create multiple templates with various transactors for their repeat CTRs so that only the date and amount need to be entered. Seems to work pretty well; server is set to save files for five years.

dickr, we are contemplating this exact process when we switch over to e-file.

We have ours set up so that the BSA department (us), has access to all the branch directory's. Each branch has a BSA folder, they have their templates, once they complete the CTR, it goes into a review folder. This is where the Operations Manger reviews the CTR and they put it into the complete folder. We go into the completed folders and move them in our folder for filing. It works for us.

Thanks everyone for the responses!

Doug: I just learned that the BSA eFiling system has a role that you can assign called 'Form Creator'. This role allows a person to fill out a CTR, but not sign or submit and they do not need a user id to do it, just access to Adobe Reader. They can then send the form after they have filled it out to the person who signs and/or submits say via email.

Our internal teller system does automatically prompt to fill out CTRs, but it can only prefill certain portions so they usually end up having to fill in at least Section B. What we have also seen is that the person that signs the CTRs in our branches does not really review for correctness (judging by the errors we catch), which is why we review again once we get them, so maybe we should cut that out all together and just have them fill out and submit directly to us (BSA) (like dickr) since only we submit them. Thanks again - this has been so helpful!

Thanks for the additional information on the Form Creator role....Doug

We don't do a ton of CTRs, but we do e-file. For regular customers on which we have all transactor info. the branch just lists the transactor on the deposit ticket and lists any coin or cash exchange there as well. If it is a night drop, they list that instead. On our shared drive, we maintain a list of the customers for which the back office staff fill in the CTR (on AML software). Back office has to look at the deposit slips, but it saves the branches a ton of time duplicating the same CTRs on a daily basis. The system maintains the CTRs and we don't need a physical copy. Examiners have been fine with the process.

Is anyone filing discrete CTRs without having an intranet? We have over 40 offices spread out in small communities and average 50 - 60 CTR filings a week. We do efile our SARs and DEP's etc but as yet I cannot figure out how the branches can save the form securely and send it to me. I do not have access to their drives and Adobe Reader will not allow them to save the CTRs and email them to me securely. An intranet is probably not in our near future.... Has anyone else found a way to overcome this? I appreciate any suggestions.

One of our network printers is a "CutePDF Writer." The document doesn't actually print; it saves as a PDF and we can then attach it to a secure e-mail. Maybe something like that will work for you.

Seems like I remember something coming out about everyone being required to e-file as of a certain date. Does anyone know about this or was I dreaming in my sleep again?