Thread Options
#1318078 - 01/05/10 07:40 PM Suffixes when filing CTR's via paper and E-Filing
nancyg Offline
New Poster
Joined: Sep 2009
Posts: 3
When a bank is filing a CTR form via paper or E-Filing, does the suffix (Sr., Jr., III, IV) need to be included on the form or file before sending to FinCEN? If so, where do you enter the suffix?

Thanks

Return to Top
BSA/AML/CIP/OFAC Forum
#1318084 - 01/05/10 07:42 PM Re: Suffixes when filing CTR's via paper and E-Filing nancyg
Dani York, CRCM Offline
Power Poster
Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
Yes (Jr. and Sr. are not the same person). I believe it is entered as part of the last name (Ex. Doe Jr).
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.

Return to Top
#1318103 - 01/05/10 07:50 PM Re: Suffixes when filing CTR's via paper and E-Filing Dani York, CRCM
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,646
Galveston, TX
For E-filing:

A. Delete any titles, prefixes, suffixes or other descriptive information such as Mr., Mrs., Dr., Reverend, Partner, or Trustee. Do not delete suffixes which distinguish family members such as Jr., Sr., III or IV. Suffixes should be edited to follow the middle initial (e.g., Doe/John/L Jr).

B. Delete all punctuation (e.g., ‘JR.’ would be submitted as ‘JR’).

Refer to: BSA Electronic Filing Requirements For The Currency Transaction Report (CTR) (FinCEN Form 104) and Designation of Exempt Person (DEP) (FinCEN Form 110)
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1318251 - 01/05/10 09:09 PM Re: Suffixes when filing CTR's via paper and E-Filing nancyg
nancyg Offline
New Poster
Joined: Sep 2009
Posts: 3
Hello,

Thanks for your responses. So, should it be entered as part of the last name or middle initial? Is it a requirement by FinCEN? Do you know if a bank will get an error if it is not submitted with the suffix?

Return to Top
#1318263 - 01/05/10 09:17 PM Re: Suffixes when filing CTR's via paper and E-Filing nancyg
Islandgirl Offline
100 Club
Joined: Nov 2005
Posts: 173
Louisiana
When I e-file a CTR, I put "Jr" or "Sr" after the last name. E-filing will not let me enter but 1 letter for the middle initial.

Return to Top
#1318335 - 01/05/10 10:02 PM Re: Suffixes when filing CTR's via paper and E-Filing Islandgirl
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 78,646
Galveston, TX
E-filing or your software that you use for e-filing?

The actual e-filing field is 35 characters long and you are required to enter the name of individual conducting the transaction, "last name/first name/middle initial". Left justified and space filled. You must following the Name Editing Conventions shown in my previous post.

Sounds like you need to have a chat with your e-filing software provider.

You would be amazed to the e-filing software providers that don't know the rules. If your audit is not analyzing your actual submission files (not your software reports), there may be other erros.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1416100 - 07/16/10 06:03 PM Re: Suffixes when filing CTR's via paper and E-Filing rlcarey
1banker Offline
New Poster
Joined: Jan 2009
Posts: 16
We had this same problem with the middle initial box using the Adobe form directly from BSA E-Filing. We called the e-filing help desk and they said the only way to enter the suffix was to add it in the Last Name box "maybe" inserting a comma after the last name. Hopefully their next form revision will correct the problem.

Return to Top
#1416159 - 07/16/10 07:01 PM Re: Suffixes when filing CTR's via paper and E-Filing 1banker
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I have always entered in the last name box:

John
E
Smith Jr
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top

Moderator:  Andy_Z