Skip to content
GeoDataVision
Thread Options
#1462271 - 11/02/10 12:20 PM CTR - using "None" for Occupation?
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
Is it acceptable to use "None" as a description of occupation in Box 13 - if the person truly hasn't ever worked?

Return to Top
BSA/AML/CIP/OFAC Forum
#1462367 - 11/02/10 02:15 PM Re: CTR - using "None" for Occupation? AuditorK
PeeWee Offline
Gold Star
Joined: Aug 2007
Posts: 254
IMHO "none" is "non-descriptive" which we are not suppose to use. Has the customer never worked because they are a housewife, disabled, etc? Those are accepable descriptors.

From the CTR instructions: Item 13. Occupation, profession, or business. If known, identify the occupation, profession or business that best describes the individual or entity in Part I (e.g.,attorney, car dealer, carpenter, doctor, farmer, plumber,truck driver, etc.). Do not use nondescript terms such asbusinessman, merchant, store owner (unless store’s name is provided), or self employed. If unemployed, or retired are used enter the regular or former occupation if known.

Return to Top
#1462382 - 11/02/10 02:42 PM Re: CTR - using "None" for Occupation? AuditorK
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
I've seen "trust fund baby" in this box, but suggest you just plug in "never employed" instead. You do not need to explain why this person has never had an occupation.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1462573 - 11/02/10 05:44 PM Re: CTR - using "None" for Occupation? Elwood P. Dowd
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
Thanks for the responses - they both confirm my thinking as well.

Return to Top
#1462609 - 11/02/10 06:07 PM Re: CTR - using "None" for Occupation? AuditorK
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
"Freeloader"?
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#1462640 - 11/02/10 06:31 PM Re: CTR - using "None" for Occupation? AuditorK
Retread Offline
Power Poster
Retread
Joined: Oct 2003
Posts: 2,548
Southeast
Originally Posted By: AuditorK
Is it acceptable to use "None" as a description of occupation in Box 13 - if the person truly hasn't ever worked?


"Politician" might work.
_________________________
Politicians are like diapers. They need to be changed often and for the same reason.

Return to Top
#1463380 - 11/03/10 07:42 PM Re: CTR - using "None" for Occupation? Retread
E.E.G.B Offline
Power Poster
E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
"Aspiring Gold-digger"
_________________________
I disbelieved what he was saying so hard, I probably created an alternate universe where it wasn't true.

Return to Top
#1463532 - 11/04/10 12:38 PM Re: CTR - using "None" for Occupation? E.E.G.B
banker1976 Offline
Gold Star
Joined: Nov 2005
Posts: 346
Mid-Atlantic
"Trust Fund Baby", really? Amazing.
_________________________
CAMS
CAFP

Return to Top
#1463695 - 11/04/10 03:16 PM Re: CTR - using "None" for Occupation? banker1976
BBoyd Offline
Diamond Poster
BBoyd
Joined: Mar 2002
Posts: 2,494
MI
My favorite is "Retired Housewife."

So -- the house isn't getting cleaned, no food is being cooked...she stays in bed all day?
_________________________
Opinions are mine and never to be taken as legal advice!

Return to Top
#1469518 - 11/17/10 10:02 PM Re: CTR - using "None" for Occupation? BBoyd
CompliKat Offline
Member
CompliKat
Joined: Dec 2009
Posts: 96
Really off topic but I adore your avatar BBoyd!!!

On topic...why is it so hard for tellers to get an occupation, I never got Trust Fund Baby but I have gotten things like "Utility", "Disable", and "Entrepeneur". Honestly, years ago when I was a teller I never found CTRs to be that difficult!

Return to Top
#1469583 - 11/18/10 12:11 AM Re: CTR - using "None" for Occupation? CompliKat
Georgie Girl Offline
New Poster
Joined: Dec 2008
Posts: 18
Actually, the Occupation field is no longer required. This was changed in the November 2008 E-Filing specification. Also, when Descrete E-Filing you can leave the field blank. So I would assume that a paper form should have the same requirements. I guess FinCEN got tired of getting all of those ridiculous made up Occupations.

Return to Top
#1469614 - 11/18/10 12:28 PM Re: CTR - using "None" for Occupation? Georgie Girl
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
From the July, 2010 instructions for electronic filings of CTRs, item 13:

Enter the occupation, profession, or business of the individual for whom the transaction was conducted. (e.g., Attorney, Securities Broker, Auto Dealer).

I would not be willing to assume.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1469767 - 11/18/10 03:39 PM Re: CTR - using "None" for Occupation? BBoyd
BSA-Eric442 Offline
New Poster
Joined: Nov 2010
Posts: 13
Ohio
Originally Posted By: BBoyd
My favorite is "Retired Housewife."

So -- the house isn't getting cleaned, no food is being cooked...she stays in bed all day?


^^ had this one two weeks ago
_________________________
KFitz said - "We have a Department on Aging (with the unfortunate acronym, DOA)"

Return to Top
#1469779 - 11/18/10 03:50 PM Re: CTR - using "None" for Occupation? BSA-Eric442
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,963
TN
My favorite - 'gay bar'. I removed the adjective.
_________________________
My Opinions Only

Return to Top
#1469849 - 11/18/10 04:22 PM Re: CTR - using "None" for Occupation? Skittles
Georgie Girl Offline
New Poster
Joined: Dec 2008
Posts: 18
From the Revision History on the July 2008 E-Filing Specification:
"The 5A Owner Record, positions 135-169, is no longer
Required, and its associated error code of 120 has been
deleted."

All prior specifications included the REQUIRED label in the field description. That label is no longer included in the field description after the change.

FinCEN has also confirmed this change.
Last edited by Georgie Girl; 11/18/10 04:23 PM.
Return to Top
#1470242 - 11/18/10 10:14 PM Re: CTR - using "None" for Occupation? Georgie Girl
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
I don't have access to the source document you quote, but admit I am intrigued. Regardless, the response I received from FinCEN's policy office today was: "The occupation field is required if known." No distinction was made between paper and electronic filing.

Trying to balance the language you quote against that clear statement, I believe leaving that field blank on an electronic filing does not generate an automatic error message, nothing more.

As far as field examiners are concerned, I still see banks criticized for not putting in the former occupation when the individual is unemployed or retired. That's true even though the CTR instructions clearly indicate that the former occupation is only necessary "if known." As the instructions do not contain any such limiting language regarding the current occupation, I would not like a bank's chances in an exam if they just said they didn't know the individual's occupation and left it blank.

As the occupation is not verifiable, it is of limited analytical value; i.e. banks simply write down whatever the person says. Hence the CTR filed by a client that indicated the person's occupation as "drug dealer."

That's what an advanced case of testosterone poisoning made him say. That's what they wrote down.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z