Answer:
First, you should quickly transmit or send it. Next, your bank should determine whether the error is an isolated instance or something that gets repeated (a systemic error) and deal appropriately with the reason for the late filing. That could mean retraining, addressing staffing, rewriting procedures to make them clearer, etc.
If examiners detect a pattern or practice of late filing, they are likely to cite the bank for weaknesses in its BSA/AML program policies and procedures.
First published on BankersOnline.com 12/5/11
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