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.
* 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.