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#1922282 - 05/12/14 06:36 PM CTR line item #20 for night deposit
sb1 Offline
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Joined: Jan 2006
Posts: 135
We are filing a CTR on a non profit unincorporated entity who has had their church account here since the 1990's. The CTR was prompted by a night deposit. We do not have any CIP information collected on this customer since it was prior to CIP requirements. Any suggestions on what to place in line item 20 or can we just check unknown since it was completed by night deposit - could we obtain their tax ID verification from the IRS and place in this spot - just grasping for suggestions?

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#1922326 - 05/12/14 07:15 PM Re: CTR line item #20 for night deposit sb1
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
If it were me, I would call and ask the church secretary for the nedded information to complete the CTR and update the bank's records. There is no reason for them not to give you the info, but if they refuse, mark the fields unknown (should be ok since the transaction occurred via night drop), document my file that I called, asked, and was refused, then decide if them refusing to supply you with the information warrants a SAR filing.
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#1922346 - 05/12/14 07:45 PM Re: CTR line item #20 for night deposit sb1
banker1976 Offline
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Joined: Nov 2005
Posts: 346
Mid-Atlantic
We have had this happen a handful of times and we've marked the Unknown box; generally occurs when the account has been with us for 20, 30 or more years, and no changes have been made to the account in all those years.

However when signers get updated on accounts like this, we do request copies of varying documents to help us authenticate the customer; most if not all account holders comply and understand we're updating files, and provided us with documentation.
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#1922447 - 05/13/14 11:24 AM Re: CTR line item #20 for night deposit sb1
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
As noted, use of the "unknown" box would be permissible, but the better practice would be to subject your customer to the CIP process (including obtaining documentary or non documentary verification) simply because they have had a reportable transaction.
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