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#2130419 - 05/15/17 01:08 PM CTR Prohibited Words
ComplianceBanker Offline
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A few of my peers and I are trying to interpret the prohibited words section of the FinCEN CTR instructions regarding prohibited words.

15. Prohibited words and phrases: Do not use the following words or variations of these words in fields:

Specifically we're determine if these words are okay to use if more descriptive words are also included. For example, if the identification type, were to state, "Other Business License" would that be acceptable even though "Other" is a prohibited word?

Thanks

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#2130420 - 05/15/17 01:12 PM Re: CTR Prohibited Words ComplianceBanker
rlcarey Online
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Well, it is either a Business License or it is not - what does the word "other" mean in this context?
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#2130423 - 05/15/17 01:34 PM Re: CTR Prohibited Words ComplianceBanker
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It was more of a hypothetical. Say for another example instead of putting Articles of Incorporation or Articles of Organization the term "Other Business Formation Documents" was included.

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#2130426 - 05/15/17 01:40 PM Re: CTR Prohibited Words ComplianceBanker
rlcarey Online
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Again - they are "Business Formation Documents" or they are not. What does "Other" mean?
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#2130429 - 05/15/17 01:47 PM Re: CTR Prohibited Words ComplianceBanker
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I listed two examples in my post as to what Other could mean. Articles of Incorporation and Articles of Organization.

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#2130430 - 05/15/17 01:49 PM Re: CTR Prohibited Words ComplianceBanker
BrianC Online
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Randy's point is that using the word other in this context is pointless. "Business Formation Documents" Is it a business license, and assumed name certificate? Whatever is in bold print on the top of the first page of the document you are review is what the document is. There is no need to call it "Other."
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#2130431 - 05/15/17 01:53 PM Re: CTR Prohibited Words ComplianceBanker
ComplianceBanker Offline
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Right, and I agree with that. Thanks everyone.

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