The CTR did not populate because the system calculation can combine only those transactions that were posted at the same time. In this particular situation the member had seven deposits within a few minutes of each other where the total amount calculated under his Social Security number exceeded the credit union configured CTR flag amount over $10,000. None of the individual amounts he deposited, however, exceed the $10,000. The total excess of $10,000 calculated placed him on your
BSA monitoring activity report. But because none of the individual deposits exceeded $10,000, a CTR did not populate to be completed.
For more information, review the
Bank Secrecy Act Monitoring Tools reference document (specifically pages 5 and 6).