Skip to content
BOL Conferences
Thread Options
#1753298 - 10/29/12 08:40 PM New CTR and NAICS Code
SunnyFL, CRCM Offline
100 Club
Joined: Sep 2004
Posts: 205
FL
We have filed 8 CTR's on a commercial customer and reported the NAICS code as Farm Product Raw Material Merchant Wholesalers (4245) when in fact it should have been Grocery and Related Product Merchant Wholesaler (4244). This code is not a required field with the new format. The question is, should we amend the CTRs for this purpose alone or just document our file about the incorrect code?

Return to Top
BSA/AML/CIP/OFAC Forum
#1753307 - 10/29/12 08:46 PM Re: New CTR and NAICS Code SunnyFL, CRCM
Gatorgirl Offline
Member
Joined: Jun 2007
Posts: 55
Florida
IMO since you used the NAICS code you would need to amend the CTR. Most of the banks in my area I have spoken to are not using the codes since they are old codes anyway.

Return to Top
#1753355 - 10/30/12 09:52 AM Re: New CTR and NAICS Code SunnyFL, CRCM
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
There is no published guidance for what types of CTR errors demand an amendment. Only field examiners claim an innate level of wisdom on this point.

In all circumstances: Either amend it or call the Helpline and see if they will tell you that in your specific fact situation it is unnecessary. (I doubt you are going to hear that.)

As suggested, the effort put into using the NAICS codes is wasted. Being forced to used the codes on the drop down list involves too much complexity when all you are delivering is a generalization rather than a specific industry. The FinCEN guidance saying you can simply describe the business in the occupation field instead is clear.
_________________________
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