Skip to content
BOL Conferences
Thread Options
#2197844 - 11/08/18 08:31 PM CTR husband and wife, IDs have different Address
Bec Offline
Diamond Poster
Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
Filing a CTR on a husband and wife.
The portfolio address is 123456 State Hwy X.
The wife's DL has an address of 123456 State Hwy X
The husband's DL has an address of 123456 State Road X

Should I make the husband's match the wife and port or should I make his match what his drivers license is showing?
_________________________
Go Packers

Return to Top
BSA/AML/CIP/OFAC Forum
#2197850 - 11/08/18 08:45 PM Re: CTR husband and wife, IDs have different Address Bec
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
I would look it up and see which of the two is accurate.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

Return to Top
#2197854 - 11/08/18 08:55 PM Re: CTR husband and wife, IDs have different Address Bec
Bec Offline
Diamond Poster
Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
While I don't disagree with your advice...if an auditor/examiner were to look at it, they would want the information to match up with the legal document issued for the customer, right? In this case, our legal document is where the discrepancy is.
_________________________
Go Packers

Return to Top
#2197862 - 11/08/18 09:04 PM Re: CTR husband and wife, IDs have different Address Bec
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
That might be an auditor's view, but law enforcement officers need an address that will take them to the location where they can interview and possibly arrest the person if wrongdoing is suspected.
_________________________
...gone fishing.

Return to Top
#2197864 - 11/08/18 09:04 PM Re: CTR husband and wife, IDs have different Address Bec
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,854
Pulling people out of the ditc...
is it possible that one has a much older drivers license and the road name changed? because a few years back my lovely state did that to a bunch, and if you had a new license it read the new way and an old one read the old way. of course, in many states, "state road" and "state hwy" are interchangeable terms and this is a non-issue for me.

but if you are concerned what your audit team will do, then i suggest picking up the phone and calling the audit manager and posing the question to them. or send them an email so you will have it in writing. same with your regulatory contact if worried about them.
_________________________
Providing alternative truths since the invention of time

Return to Top
#2197865 - 11/08/18 09:05 PM Re: CTR husband and wife, IDs have different Address Bec
Bec Offline
Diamond Poster
Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
Thank you all for you input! smile
_________________________
Go Packers

Return to Top
#2198229 - 11/14/18 08:02 PM Re: CTR husband and wife, IDs have different Address Bec
TryingtoComply Online
Diamond Poster
Joined: Apr 2013
Posts: 2,210
The West
The wife probably had it right.... ;0
_________________________
TryingToComply
CRCM

Return to Top
#2198522 - 11/16/18 08:22 PM Re: CTR husband and wife, IDs have different Address Bec
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I am reminded by one of my mentors (even at my age I pay attention to those wiser than I) that there is no earthly law decreeing that husband and wife must have the same address. It may not be the "norm," but there are doubtless thousands of married couples who don't live under the same roof.

Although many towns and cities have made attempts to eliminate lookalike addresses like First Avenue and First Street, I have seen many cases where "state highway" and "state road" refer to the same stretch of pavement.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2198523 - 11/16/18 08:24 PM Re: CTR husband and wife, IDs have different Address Bec
Valley girl Offline
Gold Star
Joined: Aug 2014
Posts: 394
TX
Check the address on the USPS website. If they are the same, it will tell you which format USPS wants it in for mail delivery purposes.

Return to Top
#2198596 - 11/19/18 02:07 PM Re: CTR husband and wife, IDs have different Address Valley girl
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,294
Originally Posted By Valley girl
Check the address on the USPS website. If they are the same, it will tell you which format USPS wants it in for mail delivery purposes.


https://tools.usps.com/zip-code-lookup.htm?byaddress
_________________________
CRCM, CAMS

Return to Top

Moderator:  Andy_Z