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#1956438 - 08/23/14 03:28 PM person's address on CTR
crc Offline
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Joined: May 2004
Posts: 150
South Dakota
Consumer presents a state driver's license with a street address that is postal mail box service (PMB1234 is listed) frequently used by RV dwellers. As allowed by CIP, we obtained a street address of a next of kin.

CTR instructions say to use a "non-location address" only if a street address is not available.

If we need to file a CTR, do we use the customer's mail service street and PMB address or the next of kin's street address?

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#1956481 - 08/25/14 01:35 PM Re: person's address on CTR crc
John Burnett Offline
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John Burnett
Joined: Oct 2000
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Cape Cod
You use the physical street address of the individual's residence. Do not use the private mailbox service's address (the dude doesn't live there). Unlike CIP rules, a business address or a relative's address isn't acceptable. If a street address is not available for the individual's residence, you can use a non-location address.
Last edited by John Burnett; 08/25/14 01:40 PM.
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#1956506 - 08/25/14 02:17 PM Re: person's address on CTR John Burnett
crc Offline
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Joined: May 2004
Posts: 150
South Dakota
He lives in a RV, stays in a location for few weeks or month then moves on. He does not have a physical address.

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#1956679 - 08/25/14 06:21 PM Re: person's address on CTR crc
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Well, he has an address at the time of the transaction, unless he's in your drive-thru on the way from one place to another when the CTR is needed.
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#1956789 - 08/25/14 08:31 PM Re: person's address on CTR John Burnett
crc Offline
100 Club
Joined: May 2004
Posts: 150
South Dakota
...the local KOA Campground, Walmart/Sam's Club parking lot, State Park or our drive through don't seem to be very useful. The next of kin is more likely to be helpful to the authorities if a CTR/SAR situation needs to be investigated.

So, I feel like I'm back to my starting point.

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#1956870 - 08/26/14 11:51 AM Re: person's address on CTR crc
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
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Next to Harvey
John answered your question accurately; e.g. the "next of kin" thing from CIP isn't relevant to the CTR.

Whether the individual lived in a stone house for 30 years or a walk up apartment for 30 days, that location is still his address. However, either could change tomorrow. If the person is an RVer and today's address is not guaranteed to be tomorrow's address there's no difference.
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