When completing a CTR for a business customer, Part 1 section 14 does anyone have guidance on how examiners view this section. We were informed by our internal audit staff that we needed to check other and put N/A for businesses. On the heading of section 14, it says if an individual, describe method used to verify identity. The instructions for Item 14 state - If an individual conducts the transact(s) on his/her own behalf, his/her identity must be verified by examination of an acceptable document (see General Instructions). For example check box a if driver's license is used to verify an individual's identity and enter the state that issued the license and the number in items e and f. If the transaction is conducted by an individual on behalf of another individual not present or an organization, enter N/A in Item 14.

We have never had any CTR returned because this has not been checked nor has our examiner ever referred to it.

I would like your experience or thoughts on this.

Thank you

See FinCEN's CTR filing information for the CTR hotline number in Detroit. Examiners' opinions don't matter when it comes to CTRs--FinCEN is the only agency with authority to issue guidance & interpretations. I'd expect your answer will be to discontinue putting "N/A" in your CTRs, because it junks them up with extraneous info that keypunchers have to read and interpret.

When the new form became available, I called FinCEN and I was told to enter "N/A" immediately after the colon and NOT to enter it in "Other." the "other" space is only intended to be used to describe the other type of identification used. I also called our rep at the IRS and was told the same thing.

This is how we have always done it.

Dolly Nugent
Vice President
Compliance Officer
Citizens Business Bank

The instructions attached to the CTR indicate you are to enter "N/A" in box 14 whenever an orginazation is identified in section A. You cannot leave any part of the CTR blank (at least without explaining why it is left blank). For instance, if section B is left blank you are to state why: completed on own behalf, multiple transactions, etc. I read one time that this was the #1 error on CTR's, although I doubt that you would hear from the IRS on this.