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#2217219 - 07/09/19 03:23 PM Email addresses on CTRs
BSA Barry
Unregistered

Do you put email address on CTRs? We do, every time. We file thousands of CTRs per year and have to type these addresses in manually, and gather the data also. What I can't figure out is, if this is an optional field, why in the world would we do it?

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#2217221 - 07/09/19 03:24 PM Re: Email addresses on CTRs Anonymous
Anonymous
Unregistered

P.S. I am referring to the customer's and conductor's personal or work email addresses, in case that wasn't clear. Not sure why we would want or need to heave all that info into the federal data vacuum.

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#2217222 - 07/09/19 03:30 PM Re: Email addresses on CTRs Anonymous
MScarn6942 Offline
Platinum Poster
Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
One point of clarity is that it's not required/not required, but rather critical/non-critical. See BrianC's post in the post linked below (5th down). If you have the info, report it.

https://www.bankersonline.com/forum/ubbthreads.php/topics/1977363
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#2217241 - 07/09/19 04:16 PM Re: Email addresses on CTRs Anonymous
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
Ours are filed via our automated AML system. We gather e-mails at account opening so it auto populates if we have it in the CTR in our software.

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#2217265 - 07/09/19 06:50 PM Re: Email addresses on CTRs Anonymous
Anonymous
Unregistered

OP here: Thanks. I guess for us it comes down to the question of whether we have the information. Many of our customers have been with us since the 80s or 90s and it is very common that their email address is not on file yet.

What we're doing is having tellers ask for the email address, and noting it somewhere, then our CTR guru has to type it in to a form.

And tellers often forget, so CTR guru has to ask for it, then teller has to call the customer - all this for a field on the new CTR which FinCEN says supposedly does "not create any new obligations to collect data..." Email address is not a component of CIP, nor would we need it for CDD (we aren't the government, so we can't monitor people based on their email address). I'm sure FinCEN wants it - but my question is shouldn't we stop asking for it?

I'm thinking: If it's on file (as it is, for the customers who have e-banking) we should put it on the CTR.
If it's not already on file, we should not attempt to gather it for CTR purposes.

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#2217266 - 07/09/19 06:53 PM Re: Email addresses on CTRs Anonymous
Complycated Offline
100 Club
Joined: Aug 2013
Posts: 168
We include it when we have it on our existing records but do not ask for it if we don't.

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#2217268 - 07/09/19 07:05 PM Re: Email addresses on CTRs Anonymous
praBSA Offline
Gold Star
Joined: Aug 2018
Posts: 348
This is a topic that annoys me with CTRs. Critical vs Non-Critical fields. Yes, we instruct our employees to complete every field we have information for. However, when regulators come in, they might say.... of the 50 CTRs were sampled, 10 were missing occupation. Well.... if we don't have it, we don't enter it..... its a non-critical field. If you want us to ask for it, make it a critical field. Damned if you do, damned if you don't. Businesses send runners constantly that aren't customers of the bank. In a lot of these instances, the CTRs are due to aggregated transactions and information wouldn't have been collected at time of the transaction. So many factors involved.

To the OP's question, all fields are "required" if you have the information, it needs to be entered. I got hung up on comparing critical and required fields for a while myself. Semantics if you ask me. In my opinion, if you want the information, make it a critical field.

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#2217269 - 07/09/19 07:09 PM Re: Email addresses on CTRs Anonymous
Anonymous
Unregistered

OP here: Thanks. And as far as my personal approach and preference, I'd far rather have two or three 20-minute conversations with field examiners a year on this subject, than pester 400 customers a year and generate countless wasted hours of tracking down info we neither have nor are required to have.

It's all the other banks out that that will mess up my plan - all the examiner has to say is "best practices" and that makes her argument irrefutable.

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