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.
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