File CTRs accurately before the deadline

Before you touch the CTR form, make sure you've got everything you need. Chasing down missing info later wastes time and can push you past the 15-day deadline.

What you'll need for individual customers

• Full legal name (exactly as it appears on their government ID -- don't guess at spellings)
• Date of birth
• Current address (residential, not a P.O. box)
• Social Security Number or alien identification number
• Occupation or type of business
• A valid government-issued photo ID -- note the type, number, and issuing authority

For business accounts, you'll also need

• The business legal name and DBA (if any)
• EIN (Employer Identification Number)
• Business address
• The person conducting the transaction on behalf of the business

Pro tips from experienced BSA officers

• If you can't get the SSN or ID, you must still file the CTR -- just note what's missing and why
• Check your core system first. Most of this info should already be on file from account opening
• If the customer's address has changed, update it in your system AND on the CTR
• For joint accounts, report info for the person who actually conducted the transaction

Now it's time to fill out the actual CTR. Take your time here -- accuracy matters more than speed. This information goes straight to FinCEN, and it can be used in criminal investigations. A sloppy CTR can trigger examiner scrutiny on your whole BSA program.

Key sections you'll complete

• Part I - Person involved in transaction -- Enter the customer's info exactly as verified in the previous step. Spelling must match their ID.
• Part II - Amount and type of transaction -- Record whether it was a deposit, withdrawal, currency exchange, or other. If there were multiple transaction types, list each one separately with its amount.
• Part III - Financial institution info -- Your bank's details. This should be pre-filled if you're using a template in the BSA E-Filing system.

Common mistakes to avoid

• Don't round the amount -- use the exact figure down to the cent
• If someone deposited $6,000 in the morning and withdrew $5,000 in the afternoon, that's $11,000 total and it triggers a CTR. Include both transactions.
• Don't forget to check the "multiple transactions" box if there was more than one transaction that day
• Watch for aggregation -- different tellers might not realize the same customer already made a transaction earlier

A note on structuring

If you notice a pattern where a customer seems to be keeping transactions just under $10,000 to avoid CTR filing, that's called "structuring" and it's illegal. Don't mention it to the customer, but do flag it for your BSA officer -- it may need a Suspicious Activity Report (SAR) too.

You're at the finish line. Time to submit your completed CTR through FinCEN's BSA E-Filing System. Don't wait until the last minute -- the 15-day deadline from the transaction date is a hard cutoff, and late filings show up on your exam report.

How to submit

1. Log into the BSA E-Filing System at bsaefiling.fincen.treas.gov
2. Select "File FinCEN CTR" from the filing menu
3. Enter all the information from your completed form (or upload your batch file if you're doing multiple filings)
4. Review the entire submission carefully -- once you hit submit, corrections require an amended filing
5. Click Submit and wait for the confirmation screen
6. Save or screenshot the BSA ID / confirmation number -- you'll need it for your records

After you've submitted

• Record the confirmation number in the field below -- this is your proof of filing
• Set the retention date to 5 years from today. Federal law requires you to keep CTR records for at least 5 years (31 CFR 1010.430).
• File a copy in your BSA records, either electronically or in your physical CTR binder -- wherever your bank's policy says it should go
• If you filed on behalf of multiple branches, make sure each branch gets notified

What if something goes wrong?

• If the system rejects your filing, you'll usually get an error message right away. Fix the issue and resubmit -- the clock is still ticking.
• If you realize there's an error after submission, you'll need to file an amended CTR. Don't ignore it -- examiners check for this.
• If the E-Filing system is down, document your attempt and try again. FinCEN knows their system has downtime, but you should still file as soon as it's back up.