We will be acquiring another bank later this year. I have a couple questions regarding CTR filing during the period after the "paper close" but before both banks are on the same operating system.

1. I would think the CTRs will be filed in our bank's name (even though the other bank's name will remain on their branch offices for a period of time) for activity on their operating system. If we have their tellers prepare the CTRs and have someone in their bank look at their cash transactions report the next day to aggregate where necessary, then have the CTRs sent to us for review (our examiner suggested this), would we need to look at our records for possible cash transactions by those customers (we do have some mutual customers)? I know we have to aggregate if we have knowledge.

2. Our bank e-files our CTRs and the other bank doesn't. Would we have to e-file their CTRs along with ours or could we e-file ours and paper file theirs until the system is converted?

Personally, I would run this one by your primary regulator to make sure you get it right. Call and ask for a BSA Examiner. They should be happy to assist.

Deena, wouldn't you have to continue to file under the other bank's name for their CTRs until their charter is collapsed?

My understanding is that, once we acquire them, they no longer exist. Most, if not all, documents will have our bank's name after paper close. I believe CTRs and SARs will be filed in our name.

Yes, and that's true even if they still operate under their old name as a "tradestyle" for your bank. XYZ Bank, division of LMNOP Bank. As far as I know, you can continue with efiling for your piece of the organization and paper filing for the acquired bank. But you should make strides as quickly as possible to be able to aggregate across the organization so you don't miss CTRs. That becomes more critical if you have customers using both sides of the organization.

Thanks, John. We're planning to at least check our system for the customers for whom the other bank completes a CTR. We do have some mutual customers, so we could have transactions to be aggregated. The period between closing and conversion is only expected to be about a month and a half, so for that period we will only aggregate where there is enough activity on one system to warrent the CTR filing (then we'll also check the other system). We also now think we can input their CTRs into our system and e-file them with ours, so the paper filing issue may have gone away.