Foreign Currency Reported on Form 104
Question: Even after all this time, we still get confused with some parts of Form 104 - the Currency Transaction Report. We've been filling it out one way, and now we've merged and find the other bank is filling it out differently. Our question has to do with foreign currency that is being deposited, and the way we put the amounts on lines 26, 26a and 27, 27a. Here are two examples of transactions that involve foreign currency:
Example 1) The customer comes into the bank with $15,000 in Canadian currency and wants to deposit the U.S. equivalent ($12,000 USD) into his account.
Example 2) The customer comes into the bank with a $13,000 USD check, drawn on his account with us, and asks that we give him the Canadian equivalent ($15,294) in Canadian currency.
We tried calling FinCEN, but unfortunately got conflicting answers.
Answer: (Editor's note - Here is the answer - Obtained by BANKERS' HOTLINE advisor, John Byrne)
Part II of FinCEN form 104, Items 26 and 27 are always in US dollars (convert foreign currency to a US dollar equivalent if required). Items 26(a) and 27(a) are only completed if foreign currency is involved. Item 26a and 27a are completed by entering the actual amount (number, no currency symbol) of the foreign currency that was deposited/withdrawn. For the two examples you provided the CTR's would be completed as follows:
Example 1)
- Item 26 Total Cash In $12,000
- Item 26 (a) Foreign Cash In 15,000
- Item 29 Foreign Country CA
Example 2)
- Item 27 Total Cash Out $13,000
- Item 27a Foreign Cash out 15,294
- Item 29 Foreign Country CA
Thanks for this response from Jeffrey Pratt, Senior Regulatory Program Specialist, Office of Regulatory Policy, Financial Crimes Enforcement Network.
Copyright © 2005 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 15, No. 3, 4/05
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