ARLINGTON, Va. — One issue that is unique to credit unions is which institution is responsible for filing a Currency Transaction Report at a shared branch.

RSM McGladrey Credit Union Services Manager Allen Leslie said that the Financial Crimes Enforcement Network has not provided any clear guidance on this. However, he pointed credit unions to FinCEN Ruling 2001-1 where Bank A and B were owned by the same holding company and a customer of A deposited cash into B. B accepts the cash under an agreement with A and sends notice to A so the funds can be credited. In that ruling, FinCEN said both institutions are responsible for filing the CTR–B because it occurred "by, through, or to you" and A because B acted as an agent of A. However, the agency already receives more than 15 million filings a year so to avoid more, FinCEN said the two institutions can contractually agree for one or the other to file. Both take the fall, however, if a CTR is missed.

Leslie recommended that regardless of which credit union files, the process must be consistent and that a copy of the filing should be shared with the credit union where the account it held. Then that credit union should check for discrepancies between the filing and the information on record.