For Miami folks:

CTRs filed for a Hialeah branch were submitted with a city of "Miami" and not "Hialeah". Address and everything else was perfect, with the exception of the City being technically incorrect. Audit finding is noting that we need to determine if it is necessary to amend these CTRs.

I am of the opinion that this is an immaterial finding that does not drive an amendment to several CTRs since Hialeah is located in Miami-Dade County and these city's titles are quite often used interchangeably and everything else related to the address was right. Seeking others opinion.

Thank you!

Would a letter addressed to the address shown on the CTR be delivered to the correct place? I'm not sure it would, since there's not an apparent overlap in zip codes between the two place names. On the other hand, if the only thing wrong with the address is the place name, I'll go dollars to Krispy Kremes (chocolate topped) the letter would get there.

The only answer that counts is one from FinCEN itself, if it's responding to inquiries in this dysfunctional governmental environment.

I recently spoke with a FinCEN representative about something similar.

If the information that would be getting updated truly changes the report, then yes, do an amendment.
Things like a major amount difference (from an accidental key error that says the amount was 11 million instead of 11 thousand) or needing to add a person who was not included or correcting an SSN/EIN. Those would be errors they would expect to see amendments for. I had specifically asked about checking/not checking the ATM withdrawal box as an example and I was told that that would be considered a "minor error" and that an amendment would likely not help the end users (i.e. law enforcement, etc.) and would not be expected.

I think that if you can do a Google search of the address and the results will pop up for Miami or Hialeah, my opinion is to fix it going forward, but not to file amendments.

Again, best option is to contact FinCEN and ask for them to follow up with an email, but be prepared for a non-committal answer from general staff.

You're too funny and yes the letter would arrive as mail is sorted by Zip Codes. There is no overlap with our zip codes fortunatley..... I wanted to avoid calling FinCEN cause I could only imagine the wait time.

Thank you and my personal favorites are the Boston Crème Pie ones!!!

Kind regards!

Thank you CULady.... those were exactly my thoughts. This one is at the bottom of the barrel for immaterial if you ask me, but just dotting my i's and crossing my t's.

Thank you again!!

Loyo111 -

The "Electronic Filing Requirements for the FinCEN CTR" has a list of fatal, validation and file errors with error correction instructions.

Errors are classified as primary or secondary dependent on their importance.

Not sure if you saw that document but wanted to throw it out there!

So FinCEN just called and they told me that they need to be amended..... go figure. Guess she wasn't from Miami.

No I didn't know. Thank you I'll look it up.