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#637649 - 11/13/06 08:14 PM CTR - Level of Tolerance for Error
Purex Offline
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Joined: Oct 2005
Posts: 181
South
Has anyone found any guidence on the level of tolerance for error a bank has for currency transaction reports. I know there are banks that let tellers file magnetically and the CTR doesn't even go through much of a review period. Our bank has teller fill out CTR, have a review person at branch, and then send to our Assistant BSA Officer for review, then it is sent to IRS. We sent out over 1800 last year. I am just trying to get a feel on what would be a fair percentage of error, in other words, has anyone had a regulator say , " Okay, your bank needs to slow down on the CTR errors. " We do a self assessment and any error the BSA Officer finds, we amend, and I feel this is a good procedure. Any feedback is much appreciated.
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#637650 - 11/13/06 08:28 PM Re: CTR - Level of Tolerance for Error
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 85,417
Galveston, TX
I'm not aware of any tolerences and normally the regulators take a zero tolerence policy on CTR filings.
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#637651 - 11/13/06 09:29 PM Re: CTR - Level of Tolerance for Error
Pinkie CRCM Offline
Gold Star
Joined: Aug 2003
Posts: 399
KY
Concur. If you miss checking the drivers license box, even though you have the actual state and id number in there, it's an error.

I have heard comments from my regulators that they look to see if your error rate has increased / decreased, but they made no mention as to what is an acceptable error rate.

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#637652 - 11/13/06 10:31 PM Re: CTR - Level of Tolerance for Error
OVERWHELMED Offline
Member
Joined: Sep 2006
Posts: 92
the south
Are errors counted against you if you find them yourself and send in ammendments as soon as they are found? I found quite a few where a box wasnt checked, the amount wasnt rounded up, etc but sent an ammendment right away. Will they consider the fact that they were corrected quickly or will they still count the errors against us?

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#637653 - 11/14/06 01:20 PM Re: CTR - Level of Tolerance for Error
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
From my experience, they'll give you credit for finding the errors yourself. Of course, it depends on which examiners you have from year to year.

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#637654 - 11/14/06 01:37 PM Re: CTR - Level of Tolerance for Error
Tocomply Offline
Platinum Poster
Joined: Nov 2004
Posts: 650
I just went through a OTS review. If you fine the error and correct it they will not hold it against you. However, when providing any copies show them the final submission not the one with the error. Once they see an error the examiner may dig deeperand expand the scope of review. They compared what we provided to our filings in FinCEN's CTR database.

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