Ultimate Guide to Currency Transaction Reports (CTR) for Credit Unions

As a credit union, compliance with financial regulations is essential to protecting your institution and members from financial crimes. One of the key reporting requirements you must follow is filing Currency Transaction Reports (CTR).

Understanding when and how to file a CTR ensures that your credit union remains compliant while helping to prevent money laundering and fraudulent activities.

This guide will walk you through everything you need to know about CTRs.

What Is a Currency Transaction Report (CTR)?

A Currency Transaction Report (CTR) is a mandatory report you must file with the Financial Crimes Enforcement Network (FinCEN) whenever a member conducts cash transactions exceeding $10,000 in a single business day.

This requirement is part of the Bank Secrecy Act (BSA) and is designed to enhance financial transparency and deter illicit activity.

Why Are CTRs Important for Your Credit Union?

• Prevent Financial Crime – CTRs help detect and prevent money laundering, fraud, and other illegal activities.
• Ensure Regulatory Compliance – Filing CTRs keeps your credit union in compliance with federal laws and prevents costly fines.
• Support Law Enforcement Efforts – These reports provide essential data to regulatory agencies investigating suspicious financial activities.

When Do You Need to File a CTR?

You are required to file a CTR when a member conducts cash transactions totaling more than $10,000 in a single business day. This includes:

• Deposits – Large cash deposits made by a member.
  Withdrawals – Cash withdrawals that exceed the reporting threshold.
• Cash Exchanges – Currency exchanges involving more than $10,000 in cash.
• Loan Payments and Other Transactions – Any other cash payments that surpass the limit.

Aggregated Transactions

If a member makes multiple smaller cash transactions within the same business day that collectively exceed $10,000, you must still file a CTR.

This prevents "structuring," where individuals attempt to evade reporting requirements by breaking large transactions into smaller amounts.

How to File a CTR for Your Credit Union

CTR filing requirements can change as regulations are updated. Before submitting a report, always review the latest instructions here to ensure compliance.

Here is an overview of what you need to do to file a CTR: 

1. Gather Member Information

• Member’s full name, address, and date of birth
• Valid identification (e.g., driver’s license, passport)
• Account numbers associated with the transaction
• Details of the transaction, including date, type, and amount

2. Complete the FinCEN Form 104

• This form must be filed electronically through the BSA E-Filing System.

3. Submit the Report Within 15 Days

• You must file the CTR within 15 calendar days of the transaction.

4. Maintain Proper Records

• Keep copies of CTRs and supporting documents for at least five years for auditing and compliance purposes.

CTR Exemptions for Credit Unions

Certain members, such as government agencies and publicly traded companies, may qualify for a CTR exemption.

If your credit union has members who frequently conduct large cash transactions, you can file for an exemption with FinCEN. However, exemptions require thorough documentation and periodic reviews to ensure compliance.

Consequences of Non-Compliance

Failing to file a CTR or submitting inaccurate reports can result in serious penalties for your credit union, including:

• Significant Fines – Non-compliance can lead to financial penalties, including fees of $10,000 for not filing within 15 days. 
• Legal Risks – Willful violations can result in criminal charges.
• Reputational Damage – Failing to comply with regulatory requirements can erode trust with your members.

Best Practices for CTR Compliance

To streamline your CTR filing process and ensure compliance:

• Train Your Staff Regularly – Ensure employees understand when and how to file CTRs.
• Use Automated Monitoring Systems – Implement software to detect transactions requiring reporting.
• Review Compliance Policies Frequently – Keep your policies up to date with regulatory changes.

Elevate Your Compliance Strategy with FLEX

Ensuring compliance with Currency Transaction Reports is essential for safeguarding your credit union against financial crime and maintaining the trust of your members.

By staying proactive, you not only protect your institution but also contribute to a more transparent and secure financial system. Download the FLEX Compliance eGuide to learn how FLEX can support your credit union’s compliance efforts.