What is the deadline to file a CTR, and how long must a copy be kept?

File a CTR within 15 days following the day the reportable transaction occurred, and keep a copy for five years from the date of the report (31 CFR 1010.306(a)(1)-(2)).

What the rule says:

• A report required by 31 CFR 1010.311 or 1021.311 must be filed by the financial institution within 15 days following the day on which the reportable transaction occurred (31 CFR 1010.306(a)(1)).
• The financial institution must keep a copy of each report for five years from the date of the report (31 CFR 1010.306(a)(2)).
• Each financial institution other than a casino must report each deposit, withdrawal, exchange of currency or other payment or transfer, by, through, or to it that involves a transaction in currency of more than $10,000, except as that section otherwise provides (31 CFR 1010.311). MSBs are pointed to that section (31 CFR 1022.311). The entries for this rule list MSBs, banks, broker-dealers, check cashers, prepaid providers and prepaid sellers.
• Reports are filed with FinCEN unless otherwise specified, on forms prescribed by the Secretary, with all information called for on the form furnished (31 CFR 1010.306(a)(3), (d)). The forms may be obtained from the BSA E-Filing System (31 CFR 1010.306(e)).

In practice:

• Count the 15 days from the day after the reportable transaction, since the rule runs from the day following the transaction.
• Start the five-year retention clock on the report date, not the transaction date.
• Check whether you are a "financial institution" under this rule. A loan or finance company whose only listed capacity is residential mortgage lender or originator is not one, so 31 CFR 1010.311 does not apply to it. It instead reports on Form 8300 each receipt of currency in excess of $10,000 in one transaction (or two or more related transactions), except as otherwise provided (31 CFR 1029.330, 1010.330(a)(1)(i)).

Timing: the 15-day filing deadline and the five-year retention period are separate clocks. Check the 8300 filing deadline in 31 CFR 1010.330 if it applies to you, since it is not covered here.

Sources

1. 31 CFR § 1010.306(a)(1)-(2): https://www.law.cornell.edu/cfr/text/31/1010.306
2. 31 CFR 1010.306 (eCFR): https://www.ecfr.gov/current/title-31/section-1010.306

This answer is general information, not legal advice. Forteris is not a law firm.