Skip to content
BOL Conferences
Thread Options
#1262596 - 10/06/09 09:31 PM CTR Completion
KomKam Offline
Junior Member
Joined: Jul 2008
Posts: 28
We have several CTR's that we complete on an almost daily basis where we have to check one of the boxes in Section B, but we also have transactor information.

For example, we have an individual with a DBA who conducts on his own behalf, but some of his employees also conduct transactions on his behalf. We also have a business account that contracts with an armored car to bring their deposits, and employees who sometimes come to the branch with cash transactions.

Historically, we have checked the appropriate box, left Section B on page 1 blank, and entered the transactors info in Section B on page 2, but I feel this is unnecessary.

Is it acceptable to check "armored car" or "conducted on own behalf" and still complete Section B on page 1? Or do we have to leave page 1 blank and fill in the information on page 2.

Thank you in advance for your help.

Return to Top
BSA/AML/CIP/OFAC Forum
#1262708 - 10/07/09 12:28 PM Re: CTR Completion KomKam
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
You can check a box in Section B and also enter information on a conductor on the same page.

Return to Top
#1263084 - 10/07/09 05:05 PM Re: CTR Completion devsfan
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The "excuse boxes" at the start of Section B are a signal that you have not supplied ALL the information on ALL the conductors. Either you have all the conductors and not all their information or you don't have all the conductors. One or more of the "excuse boxes" also explains why the information isn't complete.

Yes, you can use the front of the form even when one of the excuse boxes is checked.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1263275 - 10/07/09 07:58 PM Re: CTR Completion John Burnett
KomKam Offline
Junior Member
Joined: Jul 2008
Posts: 28
I was thinking along the same lines, but before I could try to change the way things are being done, I needed someone to back me up.

Thank you so much. You were very helpful.

Return to Top

Moderator:  Andy_Z