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#388573 - 07/20/05 05:15 PM FinCEN 314 (a)
Anonymous
Unregistered

I was wondering if anyone could weigh in on some questions I have. I read the FinCEN FAQs regarding positive or inconclusive matches. Basically it said that if you have a partial name match and no additional information match, there is no match. However, what do I do with an exact name match when none of the other info matches. Say I have John Smith with a different TIN, a DOB 5-10 years off, and no address match nor reason to believe the customer would have been out of my state (the TIN number appears to have been assigned in my state). Do I respond to FinCEN with a positive match?

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#388574 - 07/20/05 07:11 PM Re: FinCEN 314 (a)
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I would not recommend indicating a match based on name only. There are seven exact matches on my name (John S. Burnett) listed on Superpages.com as telephone listings in the U.S. alone. Only one of them lives where I live.

You need more than just a name, IMO.
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