We are having rounds with our CTR software vendor. Items 7,9,10,11,12 on the CTR says enter permanent address including ZIP code. I first took that as the permanent address of a business that has several businesses (it would be the main office) However, upon attending seminars by various orgs - I found that means the permanent addr of the place doing the transaction. (IE: McDonalds is based say in CA. Our local McDonalds does transactions - we put the local address) Or does it depend. (we also have a local drug store that has several branches - what address do we use? The corp one or the local one?)Can someone clarify this. Our vendor will not change the software back to the way they had it and we have to manually change all the addresses. Which interpretation is the correct one.

Look at the CTR instructions for address. At one time, for a business with several locatins, you had the option of using the corporate address or any address from which the transaction came. A permanent address could be either of these two.

The general instructions for the CTR do not specify if permanent is either. It is the interpretation of permanent that has us at a stand still. The vendor wants something in writing from an OCC examiner before they will change it back so we can enter the physical location instead of the corp location. I am between a rock and a hard spot to produce a copy of something showing someone what it means. Our people understand one thing and the vendor understands another.

If you have to obtain something in writing, I would contact FinCEN.

I will try there. TY