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Question & Answer
Question: We just attended a seminar on Bank Secrecy and were told that if we had a joint account, even if the relationship was husband and wife, that we had to put both names on the Currency Transaction Report-one as the person making the deposit and the other in "on behalf of". Putting the names on is no problem, but we don't usually have both dates of birth, nor do we always have both social security numbers. Is it a problem if we leave those areas blank on the person who is not making the deposit?
Answer: Yes, it is a problem. We specifically raised just this question with the representatives from FinCEN and the regulators.
Treasury cut 30% of required information off the new form-most of which they can live without. One speaker called the spaces for this superfluous information "rainy day blocks", comparing them to information "you never know…you might need it someday."
However, the social and the DOB of all the holders of a joint account are two very vital pieces of information. They must all appear on the CTR in the case of a deposit of over $10,000 in cash.
The bankers argued that requiring all socials and birthdates is going to require day-after-deposit research, as no systems known carry more information than that on the principal account holder. Look for data systems to be developed that will enable us to retrieve more information than is now available, to accommodate the requirement for all socials, and all birthdates.
In the meantime-look 'em up!
Copyright © 1995 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 6, No. 2, 11/95
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