Answer:
The people at the FinCEN Help Desk should be able to let you know if it is possible.
For future reference, I believe banks should consider the DCN to be part of their five year record retention requirement for CTR data. It does little good to be able to produce the information, but not be able to prove the report was actually filed.
My prediction is that that failure to retain the information will be cited as a record retention violation by both examiners and auditors. The fact that the instructions allow banks to fill the field with all zeros when the DCN is unknown is not a "pass," it was more likely intended to accomodate the fact that electronic corrections could be filed on paper forms that never had a DCN. The further we move from paper filing the more noticeable a missing DCN on a correcting report will be to a reviewer.
First published on BankersOnline.com 6/17/13
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