#1801105 - 04/03/13 07:26 PM
Re: CTR & RSSD number
Anonymous
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Joined: Nov 2004
Posts: 6,840
Illinois
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As has been said in every BSA related conferenence, training, or webinar that I have attended, the data points with a * are required in order to successfully submit the data to FinCen. This doesn't mean that you receive a pass to ignore all of the other fields. If you have the data available to you, you should be including it on the form.
As John, Ken, and Randy have said in a number of forums, "If they didn't want the information, they wouldn't have asked for it."
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#1801109 - 04/03/13 07:28 PM
Re: CTR & RSSD number
Anonymous
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Joined: Apr 2005
Posts: 3,663
TN
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Let's clarify that there are not required vs non-required fields. The asterix indicates a critical field, meaning if that field is not completed, you cannot submit your filing.
The expectation is that if the bank has access to the information requested, it is to be reported. The RSSD number is easily accessible (it's a few clicks to look it up on a website), therefore, you should be reporting the information.
Now, should you go back and amend all of your previous CTRs? Your best bet would be to call FinCEN and get a "ruling", then document whatever they tell you. Without FinCEN blessing your bank personally for not amending those filings, your prudential regualtor will have plenty of ammo to criticize your bank.
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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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#1824036 - 06/17/13 02:46 PM
Re: CTR & RSSD number
Anonymous
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Joined: Nov 2004
Posts: 6,840
Illinois
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Since FinCen is not verifying if the information is accurate on that field, it is true that the CTR won't reject. However, sicne law enforcement is interested in the branch location where the transaction took place, not where the CTR was filed, I can only echo Randy's sentiment. Yes, you will be subject to regulatory criticism. I'd go back and show your vendor FinCen's Q & A question #2 which states that you must discrete file until your vendor gets their issue fixed and allows you to batch file correctly. You also may want to begin looking for a new vendor.
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