I recently attended the BSA/AML Compliance Management Seminar in Tulsa, I have a question concerning CTR Part 1 2c and 2b in respect to 21 (cash in). Dollar General manager brings in deposits. I understand that she is Part 1 2b and Dollar General is Part 1 2c. Number 21 lists cash in amount and the respective account number. For Part 1 2b (manger making deposit) does that same amount go in number 21, realizing that there will be no account number affected for the manager? We have filed numerous CTRs through BSA e-filing listing no amount for number 21 for 2b (person conducting transaction for another)and all have been accepted and acknowledged. Your scenario using Amcore, Larry, Curly, and Moe left me somewhat confused on this matter and want to clarify. Thank you very much for your time.

The instructions state:

"Record the account number of all accounts involved in teh transaction(s)."

To my knowledge, that means put all account numbers that the person put money into. It has nothing to do with their ownership or how they are tied to the account. They just want to know that Manager deposited X dollars into X account.

If this is really a Dollar General Corp account, they are a Phase I customer as they are traded on the NYSE. Quit filing would be the simple solution.

Ditto. The CTR is a tracer document. Regardless of whether you are listing the person who conducted the transaction or the person on whose behalf the transaction was conducted, the same account was involved.

FinCEN does not have the capability to "proof" the CTR for inconsistencies; acceptance does not warrant that the CTR was completed correctly.

I'll add my voice to the chorus. The CTR calls for the cash amounts affecting each "person on whose behalf" and the cash amounts handled by each conductor. There should be an entry in item 21 or its cash-out equivalent in every Part I record.

And what Randy said. If it's a Dollar General owned store, you should take advantage of the Phase I exemption. If it's a franchise (and I don't know if DG has franchisees), you can't.

Would the exemption still apply if the Dolgencorp,LLC is dba Dollar General Stores?

If you go to Dollar General's latest 10-K, Exhibit 21, you will find that Dolgencorp LLC is a wholly owned subsidiary of DOLLAR GENERAL CORP


http://www.sec.gov/Archives/edgar/data/29534/000104746913003283/a2213303zex-21.htm

Dolgencorp LLC is a subsidiary of the publicly traded company. Here is a link to their SEC filings on the NYSE. You should find Dolgencorp LLC in the 8k file.

http://secfilings.nyse.com/files.php?symbol=DG

Thank you everyone for the help. I appreciate it.

Ken,
I would like to look at the CTR instructions more in detail. I cannot get the URL you gave us in the BSA-AML seminar book on page 21 to pull up on my computer. Could you please send me the link and hopefully I can pull it up that way?

Rebecca,

Try http://sdtmut.fincen.treas.gov/news/FinCENCTRElectronicFilingRequirements.pdf

The Instructions for individual field completion are in Appendix C, which stdarts on the 56th page of the PDF file.

Thank you very much.