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August 26
Keeping Bank Secrets: Things you Can Go to Jail for Telling;
Mary Beth Guard

September 8
Checkup for your RDC Program;
Susan Orr

September 10
Critical Issues on Certificates of Deposit;
Deborah Crawford

September 16
S.A.F.E. Act - Auditing for Compliance;
Patricia Cashman

September 22
FinCEN's Beneficial Owners Proposal: What It Can Mean for You;
Sonja Kriegsmann and John Burnett

September 23
Bankruptcy 101;
Sam Ott



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#1774173 - 01/09/13 11:35 AM RSSD Number
biz Offline
Platinum Poster

Registered: 11/07/05
Posts: 996
Loc: Midwest
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.

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BSA/AML/CIP/OFAC
#1774175 - 01/09/13 11:38 AM Re: RSSD Number [Re: biz]
Ted Dreyer Offline
Diamond Poster

Registered: 04/05/01
Posts: 2211

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#1774180 - 01/09/13 11:40 AM Re: RSSD Number [Re: biz]
Dani York, CRCM Offline
Power Poster

Registered: 04/13/05
Posts: 3241
Loc: TN
There is ONE RSSD id number per institution. Each individual branch does NOT have their own RSSD.
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.

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#1774186 - 01/09/13 11:47 AM Re: RSSD Number [Re: biz]
Doug Hendrickson Offline
Power Poster

Registered: 10/01/09
Posts: 3361
Loc: NE New Mexico
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 hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1774188 - 01/09/13 11:49 AM Re: RSSD Number [Re: biz]
Dani York, CRCM Offline
Power Poster

Registered: 04/13/05
Posts: 3241
Loc: TN
I stand corrected. Thanks Doug!
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.

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#1774190 - 01/09/13 11:52 AM Re: RSSD Number [Re: biz]
Dani York, CRCM Offline
Power Poster

Registered: 04/13/05
Posts: 3241
Loc: TN
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 can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.

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#1774194 - 01/09/13 11:58 AM Re: RSSD Number [Re: Dani York, CRCM]
Doug Hendrickson Offline
Power Poster

Registered: 10/01/09
Posts: 3361
Loc: NE New Mexico
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.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1774195 - 01/09/13 11:58 AM Re: RSSD Number [Re: biz]
John Burnett Offline
10K Club

Registered: 10/27/00
Posts: 30263
Loc: Cape Cod
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?
_________________________
John S Burnett
BankersOnline.com

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#1774221 - 01/09/13 12:41 PM Re: RSSD Number [Re: biz]
Comply4ever Offline
New Poster

Registered: 05/24/11
Posts: 19
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.

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#1774288 - 01/09/13 01:54 PM Re: RSSD Number [Re: biz]
John Burnett Offline
10K Club

Registered: 10/27/00
Posts: 30263
Loc: Cape Cod
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.


Edited by John Burnett (04/04/13 04:05 PM)
_________________________
John S Burnett
BankersOnline.com

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#1774423 - 01/09/13 03:50 PM Re: RSSD Number [Re: biz]
biz Offline
Platinum Poster

Registered: 11/07/05
Posts: 996
Loc: Midwest
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 #.

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#1774580 - 01/10/13 08:17 AM Re: RSSD Number [Re: biz]
DCrawford Offline
New Poster

Registered: 01/09/13
Posts: 1
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

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#1774587 - 01/10/13 08:41 AM Re: RSSD Number [Re: biz]
biz Offline
Platinum Poster

Registered: 11/07/05
Posts: 996
Loc: Midwest
Thanks Deb-
FWIW-you provided an excellant help manual for this program!

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#1774591 - 01/10/13 08:47 AM Re: RSSD Number [Re: biz]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 49725
Loc: Galveston, TX
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.
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The opinions expressed are my own, take them or leave them.

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#1790434 - 02/28/13 07:34 PM Re: RSSD Number [Re: biz]
thomasj Offline
Power Poster

Registered: 03/09/01
Posts: 4708
Loc: Running and Biking PA
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.
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#1790460 - 03/01/13 08:26 AM Re: RSSD Number [Re: thomasj]
Ken_Pegasus Offline
10K Club

Registered: 08/30/01
Posts: 17262
Loc: Another trip around the sun
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.

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The world is not a wish granting factory. Hazel Grace Lancaster

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#1790493 - 03/01/13 09:57 AM Re: RSSD Number [Re: biz]
StevenD Offline
Gold Star

Registered: 11/02/00
Posts: 363
Loc: KY
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.
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Opinion expressed are my own and not necessarily those of my employer.

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#1790609 - 03/01/13 12:29 PM Re: RSSD Number [Re: StevenD]
Ken_Pegasus Offline
10K Club

Registered: 08/30/01
Posts: 17262
Loc: Another trip around the sun
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. grin
_________________________
The world is not a wish granting factory. Hazel Grace Lancaster

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#1790620 - 03/01/13 12:39 PM Re: RSSD Number [Re: biz]
John Burnett Offline
10K Club

Registered: 10/27/00
Posts: 30263
Loc: Cape Cod
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.
_________________________
John S Burnett
BankersOnline.com

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#1790658 - 03/01/13 01:23 PM Re: RSSD Number [Re: biz]
September Offline
Platinum Poster

Registered: 01/28/05
Posts: 750
Loc: Anywhere the snow falls :)
Just wanted to say awesome link and insrtuctions. Found our branch numbers easily.

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#1790663 - 03/01/13 01:30 PM Re: RSSD Number [Re: biz]
September Offline
Platinum Poster

Registered: 01/28/05
Posts: 750
Loc: Anywhere the snow falls :)
So which branch number do you enter when there are two branches involved in the transaction?

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#1790665 - 03/01/13 01:30 PM Re: RSSD Number [Re: September]
Ken_Pegasus Offline
10K Club

Registered: 08/30/01
Posts: 17262
Loc: Another trip around the sun
Each branch must be listed separately. Each entry would reflect the RSSD of that branch.
_________________________
The world is not a wish granting factory. Hazel Grace Lancaster

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#1790680 - 03/01/13 02:01 PM Re: RSSD Number [Re: biz]
StevenD Offline
Gold Star

Registered: 11/02/00
Posts: 363
Loc: KY
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.
_________________________
Opinion expressed are my own and not necessarily those of my employer.

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#1790988 - 03/04/13 09:57 AM Re: RSSD Number [Re: Ken_Pegasus]
2old2new Offline
Member

Registered: 06/30/09
Posts: 56
Loc: tn
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.

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#1790992 - 03/04/13 10:00 AM Re: RSSD Number [Re: biz]
John Burnett Offline
10K Club

Registered: 10/27/00
Posts: 30263
Loc: Cape Cod
I suggest contacting the FinCEN Help Desk to find out if an amended or corrected CTR should be filed.
_________________________
John S Burnett
BankersOnline.com

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