I'm reviewing the CTR filing instructions and see on page 55 where they refer to armored car ruling (FIN-2013-R001). I can't find a ruling with this number on FinCEN's website.

Any ideas on where I might be able to find it?

2009 - R002

Betcha a nickel 2013 - R001 is number for the ruling (to be released before the anniversary date) that "corrects" the mess created by 2009 - R002.

They just got ahead of themselves.

Uh, I think you've looked for the wrong ruling. Try FIN-2009-R002, http://www.fincen.gov/statutes_regs/guidance/html/fin-2009-r002.html

FIN-2013-R001 is actually listed in the CTR filing instructions on the BSA Efiling website. That's what I found so confusing. I know about the 2009 ruling, but they aren't listing that.

Ken - just saw your edit. I was thinking the same thing, but didn't want to assume that was the case.

I should have gone to read it first:

If option 2d is selected because an armored car service under contract with the customer is involved in the transaction(s), the information on the armored car service, not the individual agent of that armored car service, will be recorded in Part I (see FIN-2013-R001).

You will notice that's contrary to the 2009 Ruling; i.e. they've changed the instructions before they issued the new ruling. Cool. I wonder how long they have been waiting for someone to notice.

Whoa! A little problem with the left hand not knowing what the right is doing at FinCEN, perhaps?

This information is only on the test site. I don't believe that this has been released yet. I will not rely on the information until we get an official notice of FIN-2013-R001.

The instructions for Line 24 "Aggregated transactions" also keeps changing. Sometime they refer to the requirement of a teller transaction and sometimes not. On the "live" site, they have changed the CTR version from 1.1 to 1.2 and back again to 1.1.

How we are suppossed to know what to do and when is a constant mystery for me!

We are in the process of discovering things by inches on this issue. I noticed this morning that the date on the instructions is May, 2013. The last set that I saved to mark up says October, 2012.

They have updated the instructions to support version 1.2 of the report. All of the changes made are cataloged in the first few pages.

This is a link to the October version found in the "Forms" section of the FinCEN website. I imagine it will soon be inoperative or altered to direct the clicker to the "new" instructions.

The fact that a link to the instructions is on the User Test Site does not impugn their authority. There is no rationale that would support relying on the previous set of instructions based on the fact that the administrative ruling the current instructions cite has not yet been published, but I think it's an academic issue at best.

To date, FinCEN has published new versions of the report on the User Test Site without mentioning it. They have also updated the instructions without mentioning it a couple of times. Apparently, we're just supposed to figure it out.

It's going to take a village.

It is interesting that the "live version" of the CTR has been version 1.2 since early April. The instructions may be catching up to the real world.

As an aside, I'm really anxious to read 2013 - R001. If they allow banks to ID the company instead of the individual, does that mean the armored car service, not its employee, is deemed to be the "person" who conducted the transaction? If so, then all 47 deposits made by the armored car service on the same day go on the same CTR?

Naaah, they wouldn't do that...

Just visited both the FinCEN website and the E-filing production system; could not locate CTR Version 1.2 on either, other than as an "example" on the FinCEN website. What am I missing??

You are correct. It was version 1.2 for a while in April, but is back to version 1.1 when you click on "new form" now.

Today I emailed the help desk about 1.2 vs. 1.1 since we have been filing 1.2. Got a reply but it certainly didn't answer my question as to which version we should be filing and why it changed again.

The May, 2013 instructions are gone. The October 2012 instructions are back up again. It's like a shell game.

CTR instructions are now dated July, 2013. Changes made since the last version are recapped in the "Revision History" beginning on page iv. (The armored car redux is correctly cited.)