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#2029322 - 07/23/15 07:34 PM CTR Item #9 - Type of Business
BSAsport Offline
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A relationship was established for a corporation prior to CIP. While the Bank maintains minimum identifing information and ID (Certicate of Incorporation)and applied a NAICS code to the customer profile, a description of the type of business was never recorded. Teller processed a withdrawal exceeding the reportable threshold and didn't obtain this information. Customer was contacted to provide information after-the-fact but did not answer the call and has not yet responded. CTR needs to be filed tomorrow. This field is not critical, however is required by our FI. Attempts to research the corporation through search engines have not rendered any clarity. The title of the business lends the impression it is some type of retirement company, however, we have seen situations whereby businesses have changed their type of business yet kept their name. Should we simply leave this field blank?

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#2029330 - 07/23/15 07:40 PM Re: CTR Item #9 - Type of Business BSAsport
Elwood P. Dowd Offline
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If you do not know, then you simply do not know. Leave it blank. Someone here telling you that may make you feel better. Getting someone on the Helpline to tell you that will actually allow you to put something in the file...
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#2029331 - 07/23/15 07:40 PM Re: CTR Item #9 - Type of Business BSAsport
Daisy Doodle Offline
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I would give them the business type evidenced by the NAICS code, assuming it was provided by the customer. That would be more helpful than a blank, I think.

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#2029333 - 07/23/15 07:42 PM Re: CTR Item #9 - Type of Business Daisy Doodle
Elwood P. Dowd Offline
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Sorry, if you do have a code that your bank assigned at one time, but you just have no documentation for it, then I agree, use that in 9(a) and leave 9 blank. That's not the way I read the question initially.
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#2029365 - 07/23/15 08:24 PM Re: CTR Item #9 - Type of Business BSAsport
rlcarey Offline
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Galveston, TX
I also think that I would be doing a site visit on the customer since they suddenly showed up with over $10,000 in cash and I have no idea what they do. Get on the horn to the assigned account officer.
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#2029376 - 07/23/15 08:42 PM Re: CTR Item #9 - Type of Business rlcarey
Elwood P. Dowd Offline
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I've heard the story over and over that when a bank undertakes to assign a NAICS code to all of its commercial customers they start with an investigatory process at the CIF level (includes loans, everything) in the main office. Those that remain unclassified are transferred to the branch offices who are assumed to have direct contact with the customer and be more knowledgeable about their line of business.

At the end of the process, there are always several business customers who have active accounts, but no one in the bank has a glimmer of a clue what business they are in. That's kinda scary.
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