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Currency Transaction Report (CTR) 8.0.2 - Aggregated Transaction Indicator Incorrectly Set (Doc ID 2470781.1)

Last updated on NOVEMBER 06, 2019

Applies to:

Currency Transaction Reporting - Version 8.0.0 and later
Information in this document applies to any platform.


Error message “D10 - AggregateTransactionIndicator - The element contains a Y value and the FinCEN CTR includes a party element association” from FinCEN on filing the new XML format efile.

On analysis of the Efile generated from the CTR app, the Aggregated Transaction Flag is getting incorrectly set in the Efile for a CTR thereby causing the warning above and have given the below reasoning:

a. At least one of the transactions should have a teller id.

b. Transactions included in the CTR are below the reporting requirement of $10,000.

c. Transactions in the CTR do not have Conductor ID but have Involvement Type of ‘A’ (transactions conducted on own-behalf).

Even if there isn’t a conductor on the transaction, it can be set to Conducted on Own Behalf and the account owner would have been the conductor. FinCEN is looking at the Person Involved Type to determine this. If there is a Person Involved Type of A, B, or D, the CTR will not meet the criteria to set the Aggregated Transaction Indicator. If there is only a Person Involved Type of C on the CTR and the other two conditions are met, then the Aggregated Transaction Indicator should be set.





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