Questions and Answers

No, in fact it is probably a better practice to not complete the currency transaction report (CTR) in the presence of the member/customer.  The CTR is a very detailed form that is difficult to complete on the spot as the customer is waiting to process his or her transaction.  Many organizations have their front-line staff complete more of a CTR checklist to record the essential CTR information at the time of the transaction.  Later, the BSA officer or compliance officer then reviews the CTR information collected, makes a determination as whether a filing is required, and if so, completes the filing process.  This type of a process reduces the risk of CTRs being completed erroneously and avoids delaying the customer/member.  In addition, although it is not illegal to disclose that you are completing a CTR, it is best to be discrete and not draw too much customer/member attention to the fact that a CTR is being completed. 

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