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#2194247 - 10/01/18 01:49 PM Annual CTR Exemption Review - UBO Trigger?
BSAN3rd Offline
Junior Member
Joined: Sep 2016
Posts: 32
Hi all,

I have been given the heads up by our auditor that they are going to be looking for the CTR Exemption Annual Review to be a trigger for getting beneficial ownership on our existing customers. Has anyone else built this into their program or heard of this being a requirement they will be expected to fulfill?
It seems cumbersome to require it of these customers every year and I am sure I will get push back from the retail side of things when I ask for it annually. Is anyone using an attestation of no changes instead? How are you working that into your process?

Thanks!

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#2194250 - 10/01/18 02:03 PM Re: Annual CTR Exemption Review - UBO Trigger? BSAN3rd
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
We don't plan to do this and will not if an auditor suggests it.

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#2194254 - 10/01/18 02:10 PM Re: Annual CTR Exemption Review - UBO Trigger? BSAN3rd
ColoradoAML Offline
Gold Star
Joined: Mar 2018
Posts: 289
In our annual reviews of high-risk and exempt customers this we are collecting the information. We won't be asking the customers to recertify each year going forward if we already have it on file, unless our review turns up specific information that it may have changed.

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#2194257 - 10/01/18 02:19 PM Re: Annual CTR Exemption Review - UBO Trigger? BSAN3rd
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Give them a "heads up" that you are expecting helpful advice relative to compliance, not a make work suggestion.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#2194339 - 10/01/18 07:37 PM Re: Annual CTR Exemption Review - UBO Trigger? BSAN3rd
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 1,965
The West
Find a new audit firm. Idiots.
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TryingToComply
CRCM

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#2194837 - 10/05/18 06:34 PM Re: Annual CTR Exemption Review - UBO Trigger? BSAN3rd
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,704
Cape Cod
Was that auditor a six-foot rabbit, by any chance?
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BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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