Accurately Filing a CTR on Uncooperative Customer - Richard Insley, John Burnett and Ken Golliher

<a href="http://adserve.bankersonline.com/cgi-bin/advertpro/blink.fpl?region=2&slot=1" target="_top"><img src="http://adserve.bankersonline.com/cgi-bin/advertpro/bimg.fpl?region=2&slot=1&keyword=NULL" border="0"></a>


Site Map Our Sponsors Home

Compliance Gurus
Lending Gurus
Operations Gurus
Marketing Gurus
Technology Gurus
eBanking Gurus

Print Friendly!

Email This Article!

<a href="http://adserve.bankersonline.com/cgi-bin/advertpro/blink.fpl?region=34&slot=1" target="_top"><img src="http://adserve.bankersonline.com/cgi-bin/advertpro/bimg.fpl?region=34&slot=1&keyword=NULL" border="0"></a>

Accurately Filing a CTR on Uncooperative Customer
Answer by Richard Insley, John Burnett and Ken Golliher, BOL Gurus
Guru BIOS

Question: How do we accurately report a CTR on a customer that will not provide a birth date or occupation?

Answer by Richard Insley: Refuse the transaction until the customer becomes more cooperative.

Answer by John Burnett: There is no requirement that you refuse the transaction, but you are responsible for completing the report accurately. You can inform the recalcitrant customer that it's a federal offense to cause someone to file an inaccurate or incomplete report. But ultimately, if you must complete the transaction and cannot obtain the information, you should file the CTR with a letter of explanation.

I would also recommend filing a SAR for such pig-headedness.

Answer by Ken Golliher: All of the above; refuse the transaction and file the SAR. Retaining a pig headed customer is not worth being cited for a violation on an incomplete CTR.

First published on BankersOnline.com 07/18/05

Home | Compliance | Lending | Operations | Security | Marketing | Technology | eBanking

BOL Archives Privacy Policy Important Disclaimer Recommend This Site ! Contact Us

BankersOnline is a free service made possible by the generous support of our advertisers and sponsors. Advertisers and sponsors are not responsible for site content. Please help us keep BankersOnline FREE to all banking professionals. Support our advertisers and sponsors by clicking through to learn more about their products and services.