Tell us
what you think
Our Sponsors
 |
Our Sponsors
|
Question & Answer
Question: On your last question page you said you had to file a "0" one-time CTR for banks. We have not yet done so. Banks were always exempt before. Are you sure we have to file a one-time CTR on them?
Answer: We double-checked after we had a few calls on the necessity of filing a "0" CTR for your customers which are banks. When we talked to FinCEN, we found they are getting numerous calls also. Their response to our inquiry was, "The interim rule calls for the filing of the one-time CTR for banks, BUT the final rule, when it appears, will probably remove that requirement."
Having said all that, let me pass along some very unofficial advice from the HOTLINE, which parallels what Leon Ellen, Compliance Officer, Former Examiner, and friend of the HOTLINE is doing for his bank. FILE! FinCEN's intentions may not agree with what your examiner understands.
Copyright © 1996 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 6, No. 11, 9/96
Rate This Article
Current Rating For the Feature:
| Total Ratings for this Feature: 0 |
|