We are in the process of updating our software to transition to the new CTR form. One issue that I am running into is that when entering a brand new business, it is forcing me to choose between Other and Unknown for an ID type. Our current software allows me to leave it blank. Is it going to be okay to select Unknown or is this something that I need to inquire about?

We use Other and input the tye of document we used for CIP (ie secretary of state registration, partnership agreement, etc).

Sorry, but I don't understand your question about your software.

However, as far as CTR completion is concerned, Form 112 expects you to provide identification for an entity just as you do an individual. Assuming the entity is the person on whose behalf the transaction and is conducted is your customer, then your bank should have identified it at account inception. All they need on the CTR is a recitation of what documentation you used to do that.

If you are relying on your software to populate the appropriate field on the CTR, "Unknown" won't get it done.

I haven't started using the new forms yet and it's been months since I attended training on the new forms.

Ken,
So, in that field, we'll put "Assumed Name Certificate" or "Aricles of Incorporation", etc?

Not Ken, but yes, if that is what you used at account opening.

I'm in a community bank in which some of our CTR business entities pre-date CIP requirements. Consequently, we don't have any tidy business identifying documents on file. Should we now go back and require such documentation from these long-time business customers? I know we can answer "unknown" for the ID, but will that just create a giant red flag at our next BSA exam?

RebekahL - in these cases, we went to our Secretary of State website and documented the charter number. We've been able to find the SOS for each of the businesses that we complete CTRs on.

We are also working towards "updating old signature cards," gathering CIP information on those that predated CIP requirements. We've had some success when we explain to business customers that we're updating our records.

Rebekah,

Apply the same process to an entity that you would to an individual if you had to file a CTR, but did not have identification information in the file. Get the identification now and update the file so if you have to file another CTR you won't have to look it up again. (If the customer is an entity, you may not have to ask them for anything; go with the information you find on the SOS web site.)

Clicking "unknown" in response to item 20 on the CTR for a bank customer may get you past the gates of electronic filing, but it could and should draw fire from your regulator and the person who does your independent testing.

Thank you both, your good advice confirms our thought process.