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Back filing a CTR? Who gives permission?

Question: 
If we fail to file a CTR, do we have to contact FinCEN?
Answer: 

Yes FinCEN will give you permission for a back filing. Many things can cause a missed CTR. You could have missed your annual exemption review. You can miss ATM withdrawals. You can fail to get exemptions updated when your institution merges. Work directly with FinCEN when this happens.
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