Skip to content
GeoDataVision
Thread Options
#1198897 - 06/10/09 05:18 PM Incomplete CTR
Ngoc Offline
Member
Joined: Aug 2007
Posts: 80
A teller deposited $35K into a checking account and proceeded to fill out a CTR. He didn't realize the account had multiple owners so he only collected information for the owner that was present. The Bank has incomplete CIP for the other owner and can't complete the CTR. The teller is trying to contact the customer for the information. If he is not successful in obtaining the information, can we file the CTR with missing information?

Return to Top
BSA/AML/CIP/OFAC Forum
#1199232 - 06/10/09 08:34 PM Re: Incomplete CTR Ngoc
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
If you send it with only some of the information you will get a CTR correction and have to correct it. I would really make every attempt to get the info you need from the customer.
_________________________
My opinion is mine only- not my employer's!


Return to Top
#1199293 - 06/10/09 09:27 PM Re: Incomplete CTR J2C
Ngoc Offline
Member
Joined: Aug 2007
Posts: 80
I'm just afraid that we may not get the information before the 15 days.

Return to Top
#1199298 - 06/10/09 09:33 PM Re: Incomplete CTR Ngoc
compliancemom Offline
New Poster
Joined: Mar 2009
Posts: 22
West TN
It's always better to file incomplete and on time rather than exceed the 15 day deadline. If you get the missing info later, file an amended CTR. Never, ever purposely file a CTR late....
_________________________
If only Mondays had accelerators and Fridays had brakes...

Return to Top
#1199363 - 06/11/09 01:14 AM Re: Incomplete CTR compliancemom
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Also, document the incident and what steps you took to prevent this from happening again.
Examiners want to see that you have taken measures to ensure that.

Return to Top

Moderator:  Andy_Z