RSSD Number

OK I sat in on a webinar yesterday and the speaker indicated that each branch office had its own specific RSSD number and this should be the number entered on CTRs for their transactions. She said one had to dig deep into ffiec's website in order to find them. Well I've dug and dug and the best I can do is each branch's "unique number."

Does anyone else know where I might look for RSSD numbers for each branch? Is the unique number what she could be refering to and if so do I use the unique number as opposed to the RSSD number the CTR form callls for? Thanks.

Here is the ffiec search site: http://www.ffiec.gov/nicpubweb/nicweb/SearchForm.aspx

There is ONE RSSD id number per institution. Each individual branch does NOT have their own RSSD.

I went to this web page, using our bank, and got a branch locator,which gave me the branch names and RSSDs.

http://www.ffiec.gov/nicpubweb/nicweb/BranchForm.aspx?parID_RSSD=206156

This is where I started from:

http://www.ffiec.gov/nicpubweb/nicweb/SearchForm.aspx

I stand corrected. Thanks Doug!

From the instructions:

REQUIRED (conditional). Enter the financial institution’s identification number if a code was entered in "Financial Institution ID Number Type."


Item 39 Financial institution ID number: Select the appropriate option from 39a through 39e to record the type of identification number being entered for the financial institution. Enter that number in field 39f “ID number.” Leave Item 39 blank if these options do not apply to the financial institution. See General Instruction 12 for information on entering identifying numbers.

http://bsaefiling.fincen.treas.gov/news/FinCENCTRElectronicFilingRequirements.pdf

I would say that means the institution's number, not the actual branch.

I didn't know they existed. However, I do agree with you that it appears you only need the institutions's RSSD for CTR purposes.

So the question comes: Who did the webinar and on what basis did the speaker say that the individual branch office's RSSD number should be used?

I heard the same thing in an IBAT webinar, however the speaker stated that it depends on your institutions structure and how you report things on your CALL report. The speaker said some institutions will have an RSSD for each branch and others will have one for the entire institution.

I know that when I looked up TD Bank, N.A.'s number, there was only one for the entire U.S. branch network, assigned to the home office in Delaware.

Note: I was proven incorrect. Read further down in this thread.

The webinar was put on by Gettechnical Inc. The speaker did not expand on "structure." She basically said, when you can't find it . . . dig deeper as it would be unusual for each branch not to have their own RSSD #.

Since I was the instructor I thought I would weigh in. In the CTR Handbook you received with the program you will find FinCEN's detailed RSSD instructions which says "branch". Some have branch numbers and some do not. It sounds like you do not. We had a bank in LA who had to correct 29 CTRs because they did not use branch numbers. That is what I mean by "dig deep". I don't want any of you to get caught by surprise. If you have checked then it should be fine to use the main office. Check the fincen instructions..it says branch..
deb

Thanks Deb-
FWIW-you provided an excellant help manual for this program!

Could you provide the actual title of this CTR Handbook? The FinCEN Currency Transaction Report (FinCEN CTR) Electronic Filing Requirements document has no mention of reporting the branch RSSD.

If you look up your institution on the website above, you will likely only see the main office. When you see your main office information, you have to click the "Branch Locator" button to see the RSSD Number of the various branches. In the example John used of TD Bank, there are pages upon pages of branches, each with a unique RSSD number. Our BSA/AML vendor does not currently appear to be set up to handle branch RSSD numbers, only the main office.

It also appears that Credit Unions only have one RSSD number.

Thought I would bring this topic back up since it appears that we do need to use the branch RSSD on the new forms reports.

The instructions on the SAR have always been clear, filers are to use the RSSD of the branch where the activity took place. There is no parallel instruction for the CTR.

In prepping for Top Gun we had several conversations with FinCEN. They also provided some additional information during the conference. They confirmed that, if a cash transaction reported on a CTR takes place at a branch, the branch RSSD is to be used if it has one.

An e-mail recapping the information is being sent to attendees.

In short:

* Go to the NIC web site.
* Search on the exact name of your bank
* Click "branch locator" on the upper left hand side
* The branch locator function is designed to allow you to search for branches in a single city. You do not want that for this exercise. Leave the "City" box blank and click "Submit" at the bottom of the page
* The bank's branches and their respective RSSD's will appear if they have one (not all do)
* If you are reporting a branch location on the CTR or SAR, use the RSSD assigned to that branch. If the branch does not have an RSSD, leave the box blank. Do not use the RSSD of your main office as a default entry. The instructions do not vary for batch filing vs. discrete filing.

Ken, Has FinCEN actually "published" these instructions anywhere? The version 1.1 document sure doesn't provide this level of detail about the "identifying number" at all.

No, they have not. The above is the result of multiple telephone conversations and confirmation offered by a representative at Top Gun. I believe the folks on the Helpline now have the same understanding, but if anyone is told differently I would appreciate hearing it.

To soften the annoyance this has generated, I willl speculate that the "evolutionary" CTR will eventually allow the filer to put in the RSSD and then the branch information will automatically "populate" that portion of the report.

If everyone does not see that as a significant improvement I've failed to explain it properly.

We just posted a new Banker Tool that provides a good set of instructions (with screen shots) on how to find a bank's RSSD number and any branch RSSDs that may be assigned.

http://www.bankersonline.com/tools/compliance/rssd_dc.html

Remember the last step in Ken's message above. If you're reporting a branch location for which an RSSD has not been assigned, leave the financial institution identifying number portion of the form (Item 39) blank.

Just wanted to say awesome link and insrtuctions. Found our branch numbers easily.

So which branch number do you enter when there are two branches involved in the transaction?

Each branch must be listed separately. Each entry would reflect the RSSD of that branch.

Be sure to leave item 39 "totally blank" if you do not enter an actual RSSD number. Otherwise you will trigger a warning on the form.

What would be the best next step if a CTR has been filed using the institution RSSD # instead of the branch RSSD #? And thanks so much for the correct information provided about the branch numbers.

I suggest contacting the FinCEN Help Desk to find out if an amended or corrected CTR should be filed.

I've spoken with other bankers who had the same problem. They were told by the Helpdesk that filing the correction is not necessary, just do it right from now on.

However, that's no good to you when it's you vs. an all powerful field examiner. Make the call yourself and put a memo in the file regarding your conversation. Every anecdote I have heard from bankers is that examiners are not looking at the new reports because they have had no training on them. However, they will begin looking at them on and after April 1 without a doubt.

Thank you and John both.

what if when following the directions to get the RSSD Id you run across listings for branches that are not in existence or have changed locations (but are not listed)? Who should be updating this information and/or how does it get updated?

If you think it's a problem, you might contact the NIC through the "contact us" tab at the bottom of the page, but it's not a BSA issue. FYI, I tried to contact them a couple weeks ago and it was a complete waste of time...

Thank You so much! We have struggled with how/where to find this information.

I guess I thought this might be an issue because we have one branch location listed with an RSSD number that isnt at that physical address anymore but moved slightly down the street. If this branch is used for a CTR reportable transaction am I not supposed to list the RSSD number because it wouldn't match what is listed (physical address) or should I use that close approximation (old address)? I don't want there to be a problem when we get examined for this.

Anyone questioning your choice will be using his or her version of logic, not the instructions. Call the Help Desk, write a memo to file, and go with what they tell you. This isn't something you want to talk about twice...

Thanks Ken for the advice on this.

Has anyone contacted FinCEN for their spin on this?

Ok....so since #39 is not a required field can we just skip the headache and leave it blank?

No. FinCEN expects banks to provide all of the information they can. Examiners and auditors will make certain they do.

Besides:



At some point, just plugging in the RSSD will increase the accuracy of the CTR and shorten its completion time.

If you think that completion of any of these boxes are optional when the information is available, then I think you will have a rude awakening at the next exam.

I just contacted FinCEN regarding this a couple of hours ago and they reassured me that the number they are looking for is the RSSD number that corresponds to the specific branch where the activity occurred.

That's no longer being debated here.

Yes...I guess I knew that but was hoping for the best. This is actually quite minor considering what's going on in the lending side.

Well, I have heard rumblings that the regulators are fully prepared to pull out the $500 per form negligence filing CMPs on banks that don't get this conversion to the new forms correctly.

I want to be a Walmart greeter..

We had always filed paper in the past and in June of last year went with Verafin for AML and report filing. I had never heard of a RSSD number until quite recently. Verafin has rolled out the new version of the CTR and we have been using that for quite a while now. This problem is that they do not have a place for us to put in the branch's RSSD #. They are working on a fix and I am sure plan to have it completed before 03/31/2013. My question is - will I have to back file the CTR's that have already been submitted through Verafin even thought the new form is not required until 04/01/2013?

There's a post above recounting the fact that banks who did not realize how specific the requirement is were told by FinCEN that they did not have to file corrections on prior reports; they were just told to "Go forth and sin no more." My observation is that's only good advice when the bank made its own phone call and can document who they spoke with.

That's a decidedly different circumstance than knowing it's required and not doing it for a period of time yet to be determined. (If your software can't do it correctly, you could file discretly without using the software; there is no issue of impossibility.)

You're going to need to call FinCEN and get their answer to the question.

Thank you.

"This problem is that they do not have a place for us to put in the branch's RSSD #."

My next question would be - what other boxes on the CTR have no provisions to make proper entries??

If we are only showing 20 out of 25 locations in our state, what should we do?

If the branch where the transaction took place has one, use it. If it does not, leave it blank.

FWIW...I left a message at FinCEN with regards to the RSSD numbers. I told them we had been using the BANK RSSD number and not the branch numbers and asked for guidance on how to proceed. I received a voice mail back stating that they have had many calls from banks with the same issue. He stated he is forwarding my message to compliance and sometime in the near future they will issue a statement on how to proceed with the incorrect filings. In the meantime, start filing with individual branch numbers if you have them.

FiServ is our AML provider, and we just installed the update. They pull the main bank RSSD number not the branch RSSD, so we have to go to our Notepad file before we efile and change the script to the branch numbers. This is just until FiServ has a solution, but it will be tedious. Thankfully, we hadn't sent any files yet with the new CTR.

We are also a FiServ bank using AML Manager. Per our request, they added our branch RSSD numbers yesterday and the issue was fixed in one day.

Ken, I took your advice and called FinCEN. They took info and told me they were discussing this problem. I received a call yesterday and in our case we do not have to refile, just use the correct # which we have already started. Have documented and will now hold our breath for the next "bump in the road" Thanks for all the time you and the others spend here helping us.

Sorry to bump an old thread - but couldn't find an answer anywhere.

What about "virtual" branches? For example - fraud that happens through online account opening? Or cash transactions (CTRs) conducted through armored car & not processed at a branch?

We considered these to be housed at our "main branch" - so would we use the main branch RSSD? The FI's RSSD? or in this case, leave it blank?

The FinCEN CTR was not designed to fully describe transactions that did not take place at an office of the filing institution. As indicated in post 1854087, I believe you must include the dollar amount on the CTR, but there is no way to list where the transaction took place because it did not take place at your branch.

But I'm assuming there were multiple transactions and the "unbranch" transaction was being aggregated... You didn't say that. If you have something to report and no bricks and mortar facility was involved, you must have a location in order to submit the report...the only possibility is the main office and its RSSD. I wouldn't do it without calling the Helpline first, but I see no alternatives.

This is a case of our "Armored Car" Loomis - they conduct the transactions at their facility and send us the tickets for processing.

So should I use the branch where the processing of the tickets happened? (which is our main branch & RSSD)

I'll contact e-filing too.