If I were a compliance officer, I do believe I would make up a master list of forms used within my institution, and I would annotate it with information about the version, the date we started using it, and any other pertinent details. That way, it would be possible to tell at a glance when someone within the institution (or an examiner!) asked "What form are you using for __________?").
It's time to check which form you're using for Currency Transaction Reports. If you are still using Form 4789, you will soon have to make a switch. FinCEN modified the Currency Transaction Report, IRS Form 4789, to facilitate the recording of the movement of foreign currency at the request of law enforcement users. The revised form adds two currency reporting entries to Part II - one to report foreign cash in, and the other to report foreign cash out.
The revised form is FinCEN Form 104. The old form 4789 will be accepted until August 31, 2004. After that date, the new form must be used. At your option, the new form may be used prior to the 8/31/04 deadline.
Keep in mind that FinCEN Form 104 is a fill-in form using Adobe Reader 5.0 or higher software (as opposed to a form you just print out and complete on paper). Check to make sure the individuals who will be completing CTRs at your bank have the correct version of the Adobe Reader. They may need to download an upgrade. If you haven't used a fill-in version before, here's a hint: Click on the "T" tool in the Acrobat Reader toolbar. Then, you're ready to type!
The original version appeared in the Febuary/March 2004 edition of the Oklahoma Bankers Association Compliance Informer.
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