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#1228550 - 08/06/09 06:51 PM CTR and CIP
bsarockstar Offline
Junior Member
Joined: Aug 2009
Posts: 32
At one of our branches a customer deposited over $10,000 in cash to a joint account with her father. Her father is in a nursing home and he is CIP exempt. The CTR has to be filed but we do not have a drivers license or other verification to enter on Part 1 (#14), Section A on page two. Will FinCEN return this? We do have his SS#, DOB, and occupation. I would appreciate any input to this. Thank you!

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#1228558 - 08/06/09 06:53 PM Re: CTR and CIP bsarockstar
bsarockstar Offline
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Joined: Aug 2009
Posts: 32
Jessica

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#1228560 - 08/06/09 06:54 PM Re: CTR and CIP bsarockstar
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
You can check "other" and put NA. The instructions say...

"If the transaction is conducted by an individual on behalf of another individual not present, or on behalf of an entity, check box “14d” “Other” and enter “NA” on the line provided."
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#1228589 - 08/06/09 07:05 PM Re: CTR and CIP Kelsey D
bsarockstar Offline
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Joined: Aug 2009
Posts: 32
Thank you very much. I second guessed that part of the instructions since it wasn't done "on behalf" by just a random person - it was done by the joint owner.

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#1228641 - 08/06/09 07:25 PM Re: CTR and CIP bsarockstar
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,963
TN
I have a question, though. How can the father's CIP be exempt? Banks may have different requirements for elderly individuals, but they aren't exempt from CIP.
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#1228689 - 08/06/09 07:43 PM Re: CTR and CIP Skittles
bsarockstar Offline
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Joined: Aug 2009
Posts: 32
He is CIP exempt because his account was opened before October of 2003.

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#1228718 - 08/06/09 07:57 PM Re: CTR and CIP bsarockstar
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,963
TN
OK. Now that makes sense. Thanks for humoring me with my question.
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#1228823 - 08/06/09 09:00 PM Re: CTR and CIP Skittles
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
I have the following in my BSA Policy ....

Identification of elderly or disabled persons who conduct reportable transactions:

• Certain elderly or disabled persons may not possess identification documents that would normally be considered acceptable by the Bank. Therefore, and only if no other form of acceptable identification is available, The Bank will accept as appropriate identification a social security, Medicare, Medicaid or other insurance card, along with another document that contains both the name and address of the patron (e.g.: an organization membership or voter registration card, utility or real estate tax bill).

• The document will only be accepted and the transaction concluded if the Bank is confident that the elderly or disabled patron is who he says he is.

• If the above conditions are met, the CTR should be completed with the words “elderly” or “Disabled” in Box 13, and the method of identification, such as “Social Security Card” and “(name of organization) Membership Card Only ID” in Boxes 14d-f.

• The above procedure shall also be used for elderly and disabled patrons when conducting reportable cash purchases of monetary instruments and completion of the Transaction Log.
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#1228831 - 08/06/09 09:07 PM Re: CTR and CIP WonderWoman
bsarockstar Offline
Junior Member
Joined: Aug 2009
Posts: 32
Thank you! Good info.

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