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#1301924 - 12/09/09 06:15 PM CTR completion: acceptable id
GottaLuvIt Offline
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Joined: May 2009
Posts: 48
Bear in mind that I am fairly new to BSA... an individual cashed a check drawn on our bank which triggered a CTR. The indiviual has had in past, accounts with our bank, which are now closed. When the accounts were originally opened, customer was exempt from CIP therefore identification documents were not obtained. Individual has no picture id for whatever reason, but did provide both a copy of social and birth certificate on the date check was presented for cash. When completing line 14 of CTR, what is the correct information to provide? select other and provide account type and number of closed account or birth certificate along with certificate number?

The ssn and date of birth on docs provided do match what bank already has on file.

I appreciate any recommendations.

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#1301950 - 12/09/09 06:45 PM Re: CTR completion: acceptable id GottaLuvIt
Auditor247 Offline
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Auditor247
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Posts: 140
What type of entity is it since it was exempt from CIP?

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#1301984 - 12/09/09 07:09 PM Re: CTR completion: acceptable id Auditor247
GottaLuvIt Offline
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Joined: May 2009
Posts: 48
not an entity, he is an individual consumer

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#1302119 - 12/09/09 08:54 PM Re: CTR completion: acceptable id GottaLuvIt
nemsi Offline
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Joined: Nov 2005
Posts: 383
I'm assuming that he was a known customer on 10/1/03? is the individual elderly or disabled?

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#1302278 - 12/09/09 10:54 PM Re: CTR completion: acceptable id nemsi
GottaLuvIt Offline
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Joined: May 2009
Posts: 48
Yes, he was a known customer prior to 10/1/03, but he is neither elderly or disabled.

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#1302328 - 12/10/09 02:44 AM Re: CTR completion: acceptable id GottaLuvIt
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 80,337
Galveston, TX
You needed an ID to cash a check for a non-customer. That is what he is now. Unless, the customer is elderly or disabled and you have board approved policies addressing this in a manner that complies with Administrative Ruling 92-1. Refer to page 95 of the Examination Manual or the Admin Ruling below:

http://www.ffiec.gov/bsa_aml_infobase/pages_manual/regulations/Ruling_92_1.pdf
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#1302393 - 12/10/09 01:54 PM Re: CTR completion: acceptable id rlcarey
Aggs Offline
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Aggs
Joined: Nov 2009
Posts: 1,331
Hoosier Country
Originally Posted By: rlcarey
You needed an ID to cash a check for a non-customer.


shocked That was my gut reaction. How did this transaction even get approved without and ID? This former customer's decision to not have any picture ID does not override BSA requirements. I would have told my teller to refuse to cash the check unless proper ID was presented.

Also, at what point does the CTR get completed? It should be completed by the teller/branch employee at the time of the transaction - which ensures that all the information needed from the customer is obtained.

I would be looking at your BSA policy and CTR procedures immediately to close any loopholes.

Unfortunately, I don't see an easy fix for your problem though - unless you can call this person and get a number of his picture ID from him. But since you say he doesn't have picture ID, that won't help you with anything.

The transaction did happen and you have to file the CTR. In the field I would put in "no picture ID provided; non-customer". Just be prepared to be dinged for this by your regulators and internal auditors.
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#1303181 - 12/10/09 09:35 PM Re: CTR completion: acceptable id Aggs
GottaLuvIt Offline
Junior Member
Joined: May 2009
Posts: 48
Individual did provide his social security card and his birth certificate as proof of his id. The social and dob did match what we had on file from his previous but now closed accounts so we do know he is who he claims to be, he just doesn't have a driver's license.
Our policy does allow for exceptions for individuals who do not have a driver's license or photo id, but it only sites as examples elderly and disabled individuals. I agree there's a loophole to be closed.

Thanks for your input!!

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