I know the instructions say that we may not use a PO Box by itself as an address in Part I. I'm curious though. What would happen if we did submit a CTR with only a PO Box? Would the CTR be returned for correction or would it just be written up by examiners/auditors?

Don't know. I would suggest that you obtain the physical address and file an amendment and not wait to find out.

Oh we haven't filed it yet. When I sent the CTR back to the responsible teller, she questioned what would happen if we submitted it with a PO Box like she had completed it. I didn't know what to tell her. I wanted to say it would be returned to us.

It may not be returned - but it would definitely be written up by an examiner/auditor ... & that is something you really don't want.

Ask her how well she looks in stripes?

Just tell her it's unacceptable and if you're the BSa Officer/person responsible for filing CTR's that you will not submit it that way, knowing it's wrong (refer to CTR instructions).OR you can just tell her it's because you said so.

I don't think she was refusing to get the additional information for the CTR, she was just wondering what would happen if we submitted it that way. I wield a pretty big stick when it comes to BSA compliance

AuditorK - from experience, I think these two things would be likely to happen:

"Failure to furnish information required in CTR/Section 103.27(d) requires that a covered financial institution furnish all information called for in CTRs filed."

And if the subject of the CTR was a customer of your institution, and the reason for using a PO Box was that you did not have a physical address available, then also:

"Failure to obtain minimum information prior to account opening/Section 103.121(b)(2)(i)(A)(1) through (4) specifies the information that a covered financial institution must obtain from the customer, at a minimum, prior to account opening."

P.S. of course, in our examiner's defense, that wasn't the only thing we had left out of our CTRs back then. Prior to the time I was involved in the process, we had filed with occasional blank TINs, blank DOBs, blank occupations, or missing signatures, in addition to several with P.O. Boxes instead of physical addresses. We have been obliged to ensure that does not happen anymore.