How do I start preparing for the new Beneficial Ownership/CDD rules?
What have FinCEN’s geographically targeted orders required banks to do?
I have a BSA question about Phase I exempt customers. I know that Phase II customers' savings accounts can't be exempted, but what about Phase I customer savings accounts? At my institution we have a government entity but they only hold savings accounts with us. Would they still be considered Phase I exempt in our institution at all? And if so, would we have to perform a yearly review on them?
When the owner of an ATM resides in a state that requires the ATM be registered refuses to register that ATM; do you file a SAR on that customer for failure to provide documentation? If a SAR is required, does the continuous SAR filing rule apply until the customer complies?
How do you get a DCN number if the acknowledgement is no longer available on the BSA entry site?
I am seeking some guidance regarding the designation of exemption for a customer that mutually owns two businesses and conducts activity for both with our bank. He is a common owner listed on both accounts and therefore CTRs have been filed on both businesses on a single Currency Transaction Report by selecting the multiple persons and combining both businesses' aggregated transactions for reporting.The two businesses have separate accounts and tax ID numbers, the addresses and phone numbers listed are different as well. Transactions do not intermingle between the businesses and are clearly separated; the only common denominator is one of the principal owners of the businesses.When attempting to exempt the businesses can they both be combined under one Designation of Exemption? If not, only one of the businesses qualifies on its own to be exempt, would we be required to amend prior Currency Transaction Reports to separate the two businesses? Or have we been filing incorrectly to begin with?
I am trying to fill out the new CTR form and do not know how to do the boxes and blanks when a person comes into the bank and makes a deposit for a business. On the old form, we put the business name and EIN in the PART 1 section A and then put the person who conducted the transaction in Section B of Part 1. The new form #20 - is this info on the person that actually makes the deposit? I would think I check box 2c but then I do not know where to put the employee's info. I see the + - buttons at the top but do not know if this is when you use them. Any help would be great.
I just received two amended CTRs I had filed on 9.11.11 before they changed the rules for amended CTRS. At the time I attached a amended form with just the information that was incorrect on the original CTR. The rule changed on 10.31.11 stating that you made out a complete new CTR indicate it as amends prior report. So now it is 2013 and I have two CTRs to try to efile and can't find any instructions anywhere on how to do this. I tried to file FinCen CTR but it asks for a DOC # 14 numbers long; which of course I do not have. Do you have any idea where to find the documentation to show how to do this?
In a training last week it was brought to my attention on the new CTR form that it is requiring the ID collection of an entity. In the past this has never been the case and in the FFIEC manual it specifically refers to individuals. FinCEN has said that there is nothing new to the forms except the collection of the new fields. Not in any webinar or documents that we received from FinCEN said anything about identifying document collection of an entity for a CTR. The only thing I have seen regarding this is actually on the form from the help box in the ID field itself. Is this something we have to collect going forward?
Are indirect auto finance companies required to comply with SARs reporting?