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New CTR A Reality

October 1, 1995 Set As A "Start-Up" Date
We're pleased to be able to include with this newsletter, for our subscribers, an advance copy of the new Currency Transaction Report (CTR), Form 4789.

Please note this is an ADVANCE copy, and is to be used for familiarization and TRAINING PURPOSES ONLY. It is not to be used for reporting purposes until October 1, 1995.

We're indebted to the Financial Crimes Enforcement Network (FinCEN) Office of the Department of the Treasury, and the Internal Revenue Service in Washington for making it possible for us to send the 4789 advance copy to you.

The new CTR requires only the basics: who did it, on whose behalf it was done, the amount, a description of the transaction and where it occurred. It has reduced the amount of information required by approximately 30% (from 98 to 64 fields). The purpose of the revision is to reduce financial institutions' reporting burdens without compromising the needs of law enforcement.

No More "Suspicious Transaction"
There are some major changes in the new CTR. One that will cause a large sigh of relief is the removal of the "Suspicious Transaction" box. Suspicious Transactions will be reported only on the new Criminal Referral Form (or whatever its new name may be!). Pam Johnson, Assistant Director for Financial Institutions Policy, reports that FinCEN is working hard to get the new form ready so that it will also be in place for a start-up date of October 1.

Multiple Transactions Still On
Multiple transactions is one of the reporting areas that came off the original draft, then went back on, then came off, and-you'll note-is back on…but with much less required information. The new CTR has only one area to describe the types of multiple transactions and the zip code requirement has been eliminated.

"On Behalf Of" Moved
There is a reversal of "parts", in that the "on behalf of" now appears first on the report. It is so clearly marked that it should cause you no problems in your training.

Number Of $100 Gone
There is no longer a need to count the number of $100 bills-which was always a time consumer for the teller. If, however, the number of $100 bills is unusual, it should be reported as suspicious.

Don't Use Until October 1!
Details of filing are provided in the advance copy. If you have questions about the new Currency Transaction Form, you can call (800) 949-2732 to reach a representative of FinCEN.

Please remember-don't use the form for filing until October 1. You may order a supply of 4789s after May 18, by calling (800) TAXFORM or (800) 829-3676.

Copyright © 1995 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 5, No. 8, 5/95




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