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#1839901 - 08/06/13 06:32 PM No info on CTR benefactor - grandfathered CIP
crbfoster Offline
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Joined: Mar 2012
Posts: 12
Oklahoma
A CTR was created for a deposit on a joint account. The man was present and conducted the transaction into an account for him and his daughter (not present at time of transaction). Although she is a benefactor, we do not have information for certain "critical fields" as she was grandfathered in prior to the enactment of the BSA. We are not having much luck contacting the customer to gather the required info. Since she was a customer before the BSA and CIP rules, should we complete the CTR by checking "Unknown" for those critical fields? Is there any guidance out there that I am overlooking? The only thing I know of is that the CTR FAQs say that the new form does not impose any new informmation gathering requirements and that we should include what we have on record for the customer or what current BSA/CIP rules require.

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#1839910 - 08/06/13 06:51 PM Re: No info on CTR benefactor - grandfathered CIP crbfoster
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,346
Cape Cod
Both of the account owners are persons on whose behalf the transaction was completed. Submit a CTR with two Part I entries: one for the gentleman checking item 2a and the other for the daughter, checking item 2c. In the daughter's information provide what you have and respond "Unknown" for those fields for which you have no informaton (but only those fields).
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John S. Burnett
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#1839911 - 08/06/13 06:52 PM Re: No info on CTR benefactor - grandfathered CIP crbfoster
NotDoneYet Offline
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NotDoneYet
Joined: Jul 2010
Posts: 482
PA
We have submitted a CTR where info for the person benefiting from the deposit was not complete for the same reason. Never heard anything.

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#1839934 - 08/06/13 07:20 PM Re: No info on CTR benefactor - grandfathered CIP crbfoster
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,346
Cape Cod
The edits that FinCEN aspplies to the CTR submission are minimal. From a practical perspective, your most potentially severe critic will be an examiner from your federal prudential regulator. Be sure that you've made a reasonable effort to get the information and/or document well the reason for the incomplete information.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1840000 - 08/06/13 08:59 PM Re: No info on CTR benefactor - grandfathered CIP crbfoster
crbfoster Offline
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Joined: Mar 2012
Posts: 12
Oklahoma
Thank you John! That is exactly how we had our template set up.

Good to know NotDoneYet.

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