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#2198872 - 11/21/18 04:28 PM NAICS Code
CoSmIc GoPhEr Offline
Junior Member
Joined: Apr 2013
Posts: 31
Are we there yet?
Found out my loan department is assigning NAICS codes to the borrower on any business purpose loan. This creates issues when CTRs and SARs are being created on these accounts since the NAICS code is assigned to the individual. I am well aware of the fact that NAICS codes are for entities only but am not sure if it would be considered an error on the CTR/SAR if a NAICS code was assigned to an individual instead.

I have reviewed the 2012 FinCEN guidance and have read the FAQ and have not been able to locate any mention of a regulatory violation if a NAICS code is included on a SAR or CTR for an individual.

We have been manually removing the NAICS codes assigned to individuals on both CTRs and SARs but it turning out to be a rather large undertaking as we file close to 5000 CTRs a month.

Thoughts?

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#2198887 - 11/21/18 05:46 PM Re: NAICS Code CoSmIc GoPhEr
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,458
Somewhere
5,000 CTR's per month?????????? Holy moly!!!! Please tell me you've utilized all the exemptions that you can!!!

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#2198892 - 11/21/18 06:18 PM Re: NAICS Code CoSmIc GoPhEr
CoSmIc GoPhEr Offline
Junior Member
Joined: Apr 2013
Posts: 31
Are we there yet?
Every....single....one!!!

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#2198901 - 11/21/18 06:56 PM Re: NAICS Code CoSmIc GoPhEr
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
I have filed both CTRs and SARs that include NAICS codes on individuals and have not had FinCEN or my regulators or outside auditors say anything. I also couldn't find anything that said it was prohibited.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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#2198902 - 11/21/18 06:57 PM Re: NAICS Code CoSmIc GoPhEr
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
P.S. I hope your bank is charging the business that trigger CTRs sufficiently to cover the amount of work you are doing for filing.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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