CTR filing that stacks every cash day to the $10,000 line, sources every conductor field, and files only what the BSA Officer approves
Every cash day stacked by member, and CTRs filed with no blank conductor fields.
See one case, screen by screen ↓CTR Filing & Exemptions handles CTR filing for banks and credit unions: cash operations aggregate cash activity, file CTRs on time and keep DOEP exemptions current. Seven agents stack every cash transaction by person and business day, draft each currency transaction report with the source of every field, read missing conductor IDs from teller images and run the annual exemption reviews. The CTR Specialist prepares each batch and the BSA Officer approves it before it is filed.
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CTR filing looks like arithmetic: cash over $10,000 in one business day, by or for one person, reported within 15 days. The work is in the stacking. Teller deposits, ATM deposits and night drops at different branches live in three systems and must be added up by person and business day, with all branches counted as one institution, night, weekend and holiday deposits moved to the next business day, and cash in never netted against cash out.
The weak field is the conductor. The rule asks for the name, address and the ID used by the person who presented the cash, and “known customer” is prohibited outright, yet tellers under queue pressure key it anyway. The CTR Specialist chases the branch while the 15-day clock runs. Around the filings sit the exempt persons, each to be designated on FinCEN Form 110 and reviewed every year, and the near-line patterns that belong with alert triage without a word to the member.
Estimated split of a CTR Specialist's working time on one business day's batch of about 22 CTRs at a credit union of the demo's size, by hand and with the agents. It leaves out the time a branch takes to answer. Our arithmetic, kept modest.
Seven agents stack the cash day, read conductor IDs from teller images and draft each CTR; the Specialist prepares and the BSA Officer approves.
At Norrell Federal Credit Union, Harbor Light Laundromat LLC, which runs two laundromats in Bramford, deposited cash three times at two branches on Tuesday, October 6, 2026. It is Friday, October 9. Here is how that day becomes a filed CTR, screen by screen, in the working solution.
Keisha opens on the cash day: 11,640 cash transactions stacked overnight by member and business day (teller 9,180, ATM 2,214, night drop 246). Twenty-three members crossed the line and 21 CTRs are complete, with 2 waiting on branch data; 14 came near it. Calloway Auto Repair took in $8,000 and paid out $6,000, never netted, so no CTR.
What needs you: “Harbor Light Laundromat's conductor ID found in the teller image (day 3 of 15).”
Harbor Light's Tuesday is three blocks: a $4,200 teller deposit at Westbrook at 10:14 AM by its owner, Denise Harlow; $2,350 at the Westbrook drive-up ATM at 1:52 PM, conductor not known; and $3,900 at Main Street at 3:41 PM by Andre Voss. Together they reach $10,450. Cash out sits apart at $0, never netted, and the CTR is drafted beside the stack with every field sourced.
“Over the line by $450: CTR drafted.”
A $1,980 night drop at Main Street sits outside the stack. The night depository log shows bag NB-55102 dropped Tuesday at 9:12 PM and opened Wednesday at 8:31 AM under dual control, so it counts on Wednesday, October 7, the next business day, citing 31 CFR 1010.313(b). Wednesday's stack is $5,120: no CTR.
At Main Street the teller keyed the conductor's ID as “Known member”, a notation 31 CFR 1010.312 prohibits. The agent asked Rosa Delgado's branch on Wednesday at 2:16 AM; the teller was out until Friday. Overnight it read Andre Voss's Ohio driver license from teller image TC-20261006-MS-0441, page 2, with a confidence per field (ID number 0.97), and matched it to his member profile.
The Conductor Finder never accepts its own reading; below 0.95 it asks the branch instead.
Keisha compares the reading with the image and accepts it. She picks the reason, “Verified against the image”, over “Verified with the member by phone” or “Confirmed by the branch”. The ID number, date of birth and address go into Part I with the teller image as their source, and the reason goes on the audit trail.
CTR-261006-014 lists three persons in Part I: Harbor Light Laundromat LLC, on whose behalf the cash moved, Denise Harlow and Andre Voss. Part III has one line per branch, Westbrook $6,550 and Main Street $3,900, summing to Part II's $10,450. The check runs structure, required fields, tax ID types, dates, amounts, boxes and ZIP codes.
“0 errors · 0 warnings. Ready for today's batch.”
Batch B-2026-1009 holds 23 CTRs for $336,415: 21 from Thursday, Harbor Light from Tuesday and one amended CTR for Ostrander Tire & Wheel. Two stay out until their branches answer: Brightwater Car Wash (the conductor's occupation) and Delmar Vending Services (the conductor's address). Keisha prepares the batch; the approve button is not hers.
“You cannot approve this batch. You prepared it; the BSA Officer approves.”
Lorraine approves the batch. The E-Filing Clerk submits it at 10:06, and at 10:31 the acknowledgment reads 23 accepted, 0 warnings, 0 rejected. Each BSA ID is pinned to its CTR: Harbor Light's is 00000267745019, filed on day 3 of 15, with the deadline on Wednesday, October 21.
“Copies and evidence kept five years.”
Cedar Basin Grocers Inc has been exempt as a non-listed business since May 2019. Six of seven tests pass, including ineligible activities at 6.2% of gross revenue, under the 50% limit. One account, ending 2209, takes cash collected for a money transmitter: 9 deposits, $41,300 since March, and cash deposited as an agent for another person is not exempt. The agent proposes keeping the exemption and treating that one account as non-exemptible; Keisha prepares, Lorraine approves.
Rowan Pike deposited $9,400 at Lakemont, $9,600 at Granger and $9,500 at Main Street on three business days: $28,500, and no day over $10,000, so no CTR is owed. Pattern Watch handed the stacks to alert triage as AL-2026-30418. The member's online banking and the branch's teller screen show nothing, and the guard log proves it.
“Visible to the BSA team only.”
Four people at Norrell Federal Credit Union who carry one cash day from the teller line to the examiner: what their day looked like, and what it looks like now.
Seven agents stack the cash day, read conductor IDs from teller images and draft each CTR; the Specialist prepares and the BSA Officer approves.
Stacks every cash transaction by person and business day across 38 branches, 112 ATMs and night drops, treats all branches as one credit union, moves night, weekend and holiday deposits to the next business day and records the source of every block.
Identifies the conductor and the on-behalf-of party for each block, flags prohibited notations such as “known member” or “signature card on file”, reads imaged IDs and deposit tickets, matches them to the member profile and asks the branch only for what is still missing.
Fills the FinCEN CTR, Parts I–IV, with the source of every field, checks the ATM, night deposit and aggregated boxes, and writes one Part III line per branch.
Checks each CTR and the batch against FinCEN's BSA E-Filing schema and the credit union's edit checks: tax ID types, dates, ZIP codes and location amounts that sum to the total.
Keeps the 15-day clock on every CTR and escalates, submits approved batches to BSA E-Filing, reads the acknowledgments, pins each BSA ID and drafts amendments with the prior BSA ID.
Runs the annual review of each exempt person with the evidence for every test, proposes designations within the 30-day window, amendments and revocations, and drafts the FinCEN Form 110 filing.
Looks across days and branches for cash kept just under the line, hands the stacks to alert triage in the transaction monitoring system, and guards every member- and branch-facing view against any mention.
Approves every batch; never her own edits. The agents propose; a named person decides.
Ask about any member's business day, a CTR's fields, a filing or an exemption. Every answer cites its source, and some answers open the screen they describe.
Why isn't Tuesday's night drop in Harbor Light's October 6 total?
Because the rule counts it on the next business day. Bag NB-55102 went into the Main Street night depository on Tuesday, October 6 at 9:12 PM. Deposits made at night, over a weekend or on a holiday are treated as received on the next business day, so its $1,980 sits in Wednesday's stack ($5,120, no CTR). The October 6 stack is $10,450 from three deposits.
Which CTRs are closest to their 15-day deadline?
None is close. The oldest open CTR is Harbor Light Laundromat's, day 3 of 15, due Wednesday, October 21; it joins today's batch once you accept the conductor reading. The other open CTRs are from Thursday, on day 1. Two of them wait on branch answers due back Tuesday, October 13, after the Columbus Day holiday.
Is Cedar Basin Grocers still eligible for its exemption?
Mostly. It passes every test of a non-listed business: an account since 2014, 212 reportable cash days in 12 months, an Ohio corporation in good standing. Its money order counter is an ineligible activity, but only 6.2% of gross revenue, under the 50% limit. One account, ending 2209, holds cash collected for a money transmitter, and cash an exempt person deposits as an agent for another is not exempt. I propose keeping the exemption and treating that account as non-exemptible. You prepare it; Lorraine Whitaker approves.
Build the NCUA examiner pack for the third quarter
Building it now: 1,402 CTRs filed July 1 – September 30 with their acknowledgments, 9 DOEP filings, 38 annual exemption reviews, 117 branch requests and every agent step, each with its evidence. Records are kept five years from filing.
13 screens from the working solution, on its sample data. Pick one to see it large.
The business day, thresholds, clocks and exemption rules are settings. Rules set by regulation are locked; every other change is saved as a new version and takes effect when the BSA Officer approves it.
| Setting | Default | Choose from |
|---|---|---|
| Business day cutoff | 5:00 PM at branches, 8:00 PM at ATMs | Per branch and for ATMs; Granger and Lakemont close at 4:00 PM on Saturdays |
| CTR threshold | Cash in or cash out of more than $10,000 in one business day | Locked: set by regulation |
| Near-line watch | $8,000 | Stacks shown as near the line and watched for patterns |
| Internal file-by target and escalations | Day 5; the BSA Officer at day 7, the CEO's office at day 10 | Escalation steps at day 7 and day 10; the day-15 deadline is locked |
| Branch request time limit | 2 business days | Escalates to Branch Operations when passed |
| Confidence to propose an ID reading | 0.95 | Set per agent: Conductor Finder 0.95, Exemption Reviewer 0.85, Pattern Watch 0.80 |
| Frequent cash, for exemptions | 5 or more reportable transactions a year | Reportable transactions in 12 months that make a business “frequent” |
| Masking | By role | By role · Always |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample credit union data · “target” = the design goal, measured in the live solution · “estimated” = our estimate (the time split; the share of multi-transaction CTRs that needed a branch request and the hours per exemption review, at a credit union of the demo's size) · “typical” = published figures (FinCEN, Year in Review for FY2024: 20.5 million CTRs). Rules named for context: 31 CFR 1010.306, 1010.311, 1010.312 and 1010.313 (CTR filing, identification and aggregation), 31 CFR 1020.315 (exempt persons and FinCEN Form 110) and 31 CFR 1020.320(e) (SAR confidentiality). The credit union, members, businesses, people, accounts and identifiers named on this page are fictional: characters and sample data in the working solution.
CTR Filing & Exemptions handles CTR filing for banks and credit unions: cash operations aggregate cash activity, file CTRs on time and keep DOEP exemptions current. Seven agents stack every cash transaction by person and business day, draft each currency transaction report with the source of every field, read missing conductor IDs from teller images and run the annual exemption reviews. The CTR Specialist prepares each batch and the BSA Officer approves it before it is filed.
A CTR is owed for cash in, or cash out, of more than $10,000 in one business day by or on behalf of one person (31 CFR 1010.311 and 1010.313). It is due within 15 days after the business day and kept five years (31 CFR 1010.306). The E-Filing Clerk keeps a clock on every CTR, with an internal target of day 5 and escalations at day 7 and day 10 in the demo's settings.
All branches, ATMs and night depositories count as one institution, and transactions by or for one person in one business day are added together. Deposits made at night, over a weekend or on a holiday count on the next business day, and cash in and cash out are added separately, never netted. Each block in a stack names its channel, branch, time and source.
The rule prohibits it (31 CFR 1010.312). The Conductor Finder flags the notation, reads the ID from the teller image, shows a confidence for each field and matches it to the member profile. The CTR Specialist accepts, edits or rejects the reading with a reason; below 0.95 confidence the agent asks the branch for exactly what is missing.
The Exemption Reviewer lays out every test of 31 CFR 1020.315 for each exempt person with its evidence, including ineligible activities against the 50% revenue limit and cash deposited as an agent for another person. It proposes designations, amendments or revocations and drafts the FinCEN Form 110 filing; the CTR Specialist prepares and the BSA Officer approves. Many ready reviews can be prepared together.
No. Pattern Watch hands near-line patterns across days and branches to alert triage with the stacks attached, and never decides a SAR. Member- and branch-facing views never show the hand-off, teller notes are screened, and a guard log shows what the member and the branch saw.
Yes. The agents stack, read, draft and check; they never approve or file on their own. The CTR Specialist accepts every ID reading and prepares the batch, the BSA Officer approves it, and the E-Filing Clerk submits only an approved batch. Overrides carry reason codes and every step is on the audit trail.
The Agentic Solution Engine builds and deploys it from your requirements and documents: your BSA procedures, business-day cutoffs, exemption files and a sample of past cash days and CTRs. It goes live once every quality gate has passed. We will walk you through it on your own cash days first.
Every member's rating explained in one sentence, re-scored the day a fact changes.
1-min demoBSA/AML Risk AssessmentThe annual risk assessment built in days, every rating cited, refreshed each quarter.
1-min demoFinCEN 314(a) RequestsEvery subject searched and proven, every true match replied to inside the 14 days.
1-min demoWe'll run CTR Filing & Exemptions on a sample of your own past cash days and exempt-person files.