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2020/10/07
As a partner to many MSBs throughout the country, Surety Bank has a lot of practical knowledge to share that can help you grow a better business. We take our role seriously and want to provide you with all the resources you need for growth and compliance.
As you know, for any cash transaction above $10,000 in cash, a bank, Money Service Business or any financial institution is required to file a CTR on the individual or entity that is conducting the transaction. The CTR is a form where you will enter the information requested about the person or entity in which you are filing. Then you will upload that information within 15 days. You can find more information about this time frame and answers to many other questions at the link below:
https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr
In this article we’ll be covering how you should think about the process of filing a Currency Transaction Report (CTR). This is one of the most routine tasks you may have in your business, but getting it wrong could result in major complications to your business. So, let’s get into the top two reasons you may want to improve your process of filing a CTR.
For example, if you’re a Money Service Business in Miami and you have hundreds of customers that are coming in every day. A lot of those customers could be construction companies that are cashing checks over $10,000 on a daily basis. As an MSB, you would have to file a lot of CTRs. This can get overwhelming as it presents more work for your staff on top of your normal workload for your customers. However, overlooking details can cause a lot of trouble in the future.
Where you can get into trouble here is by skipping steps in the process or leaving out any necessary information on each customer. We see MSBs getting into trouble when they don’t take the time to properly fill out and submit the form for each of their customers. Missing information can cause red flags when getting audited.
At Surety Bank, we use software to help us automate a large amount of the work and make sure it is getting done correctly. When a customer comes in deposits $12,000, it would automatically notify us and then would auto fill their information. We would just have to send it in within the given amount of time. Some MSBs are still handling their CTRs manually. If this is you, we would highly recommend getting software to help automate your work and make the reporting more accurate.
As an MSB, you have a 15 day window from the time of the transaction to file an accurate CTR on time. It’s gotta be accurate. We’ve seen that some MSBs completely miss the 15 day window and it results negatively on them and their businesses.
A big part of MSBs missing their window or not filing at all for some customer transactions is due to a lack of oversight on specific account activity. For example, let’s say a customer comes in three times in one day and deposits $4,000 each time. That total deposited is $12,000. This requires a CTR on that customer and their transactions. Having software in place would help you catch this while handling this manually will result in many more human errors.
In Summary
If you want to be in business many years from now, our recommendation is to make compliance your competitive advantage. Just like keeping accurate tax records, filing accurate and timely CTRs is the kind of work that will keep you in business for the long haul.
Reach out to our BSA team through our website at mysuretybank.com/msb for more information or connect with directly our CEO by email: rjames@mysuretybank.com.
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