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#1462271 - 11/02/10 12:20 PM CTR - using "None" for Occupation?
AuditorK Offline
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Is it acceptable to use "None" as a description of occupation in Box 13 - if the person truly hasn't ever worked?

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#1462367 - 11/02/10 02:15 PM Re: CTR - using "None" for Occupation? AuditorK
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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.

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#1462382 - 11/02/10 02:42 PM Re: CTR - using "None" for Occupation? AuditorK
Elwood P. Dowd Offline
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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.
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#1462573 - 11/02/10 05:44 PM Re: CTR - using "None" for Occupation? Elwood P. Dowd
AuditorK Offline
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Thanks for the responses - they both confirm my thinking as well.

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#1462609 - 11/02/10 06:07 PM Re: CTR - using "None" for Occupation? AuditorK
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Where the heart is
"Freeloader"?
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#1462640 - 11/02/10 06:31 PM Re: CTR - using "None" for Occupation? AuditorK
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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.
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#1463380 - 11/03/10 07:42 PM Re: CTR - using "None" for Occupation? Retread
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#1463532 - 11/04/10 12:38 PM Re: CTR - using "None" for Occupation? E.E.G.B
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"Trust Fund Baby", really? Amazing.
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#1463695 - 11/04/10 03:16 PM Re: CTR - using "None" for Occupation? banker1976
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My favorite is "Retired Housewife."

So -- the house isn't getting cleaned, no food is being cooked...she stays in bed all day?
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#1469518 - 11/17/10 10:02 PM Re: CTR - using "None" for Occupation? BBoyd
CompliKat Offline
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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!

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#1469583 - 11/18/10 12:11 AM Re: CTR - using "None" for Occupation? CompliKat
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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.

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#1469614 - 11/18/10 12:28 PM Re: CTR - using "None" for Occupation? Georgie Girl
Elwood P. Dowd Offline
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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.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1469767 - 11/18/10 03:39 PM Re: CTR - using "None" for Occupation? BBoyd
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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
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#1469779 - 11/18/10 03:50 PM Re: CTR - using "None" for Occupation? BSA-Eric442
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My favorite - 'gay bar'. I removed the adjective.
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#1469849 - 11/18/10 04:22 PM Re: CTR - using "None" for Occupation? Skittles
Georgie Girl Offline
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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.
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#1470242 - 11/18/10 10:14 PM Re: CTR - using "None" for Occupation? Georgie Girl
Elwood P. Dowd Offline
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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.
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