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#1801045 - 04/03/13 02:34 PM CTR & RSSD number
Anonymous
Unregistered


I seen posted in the banker tools section instructions on obtaining a RSSD number. There is a field on the CTR #39 where you would fill in this information, but number 39 does not have a * next to it. I have not been filing this information out, is this something that in the future I should be filing out or do I need to make corrections to old CTRs to include this?

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#1801054 - 04/03/13 02:42 PM Re: CTR & RSSD number [Re: Anonymous]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 50028
Loc: Galveston, TX
FinCEN has told a number of banks to just get it fixed and do it on a go forward basis.
_________________________
The opinions expressed are my own, take them or leave them.

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#1801094 - 04/03/13 03:17 PM Re: CTR & RSSD number [Re: Anonymous]
Anonymous
Unregistered


I would think FinCen would fix their form then and mark it as required * if they are requiring that number- that would make the most sense to me, but I guess what do I know!?

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#1801105 - 04/03/13 03:26 PM Re: CTR & RSSD number [Re: Anonymous]
BrianC Online
Power Poster

Registered: 11/26/04
Posts: 2824
Loc: Illinois
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."
_________________________
I can do all things through Him who gives me strength. (Phillipians 4:13)

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#1801109 - 04/03/13 03:28 PM Re: CTR & RSSD number [Re: Anonymous]
Dani York, CRCM Online
Power Poster

Registered: 04/13/05
Posts: 3252
Loc: TN
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.
_________________________
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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#1801123 - 04/03/13 03:45 PM Re: CTR & RSSD number [Re: Anonymous]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 50028
Loc: Galveston, TX
your prudential regualtor will have plenty of ammo to criticize your bank.

And the ammo is $50 a CTR for everyone they find in which fields were not completed when the information was available.
_________________________
The opinions expressed are my own, take them or leave them.

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#1824027 - 06/17/13 10:28 AM Re: CTR & RSSD number [Re: rlcarey]
Anonymous
Unregistered


My bank has been doing discrete CTR filings using the unique RSSD number for each branch. My bank now wants to do CTR batch filings using the automated software offered by a third party vendor. However the vendor's software currently uses the Company RSSD number for all CTRs regardles of the branch location. My vendor is stating that FinCEN is not rejecting CTR batches with the Company RSSD number so there is no problem filing CTRs that way. Do you think there would be any issue with the auditors or FinCEN if my bank were to file CTRs with Company RSSD numbers only as suggested by my vendor?

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#1824035 - 06/17/13 10:45 AM Re: CTR & RSSD number [Re: Anonymous]
Anonymous
Unregistered


Yes, it would be an issue: Listed as a 'best practice' from a recently concluded OCC exam:
Ensure individual branch RSSD numbers are used in accordance with the branch originating the CTR reportable transaction.

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#1824036 - 06/17/13 10:46 AM Re: CTR & RSSD number [Re: Anonymous]
BrianC Online
Power Poster

Registered: 11/26/04
Posts: 2824
Loc: Illinois
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.
_________________________
I can do all things through Him who gives me strength. (Phillipians 4:13)

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#1824050 - 06/17/13 11:02 AM Re: CTR & RSSD number [Re: Anonymous]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 50028
Loc: Galveston, TX
Show them Question 32 at the same time explaining which RSSD number to use. There is no longer any doubt on how to correctly handle RSSD numbers.
_________________________
The opinions expressed are my own, take them or leave them.

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#1824088 - 06/17/13 11:52 AM Re: CTR & RSSD number [Re: Anonymous]
Ken_Pegasus Offline
10K Club

Registered: 08/30/01
Posts: 17327
Loc: Another trip around the sun
Quote:
My vendor is stating that FinCEN is not rejecting CTR batches with the Company RSSD number so there is no problem filing CTRs that way.


Whoever told you that is either not the sharpest tool in the shed or he's just dishonest. Brian & rlcarey have directed you to the FinCEN resource that flatly answers your question in item 2.

To paraphrase a prior post from Brian, some of the vendors decided that if a field was not labeled "critical" then it must be "optional." That's obviously wrong and it would concern me that someone who wanted to peddle something to me didn't know any better.
_________________________
The world is not a wish granting factory. Hazel Grace Lancaster

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#1824116 - 06/17/13 12:22 PM Re: CTR & RSSD number [Re: Ken_Pegasus]
Anonymous
Unregistered


My vendor still has no resolution date on this and I guess I need to go back to doing discrete filings then.
Thank you all.

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