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#756272 - 06/19/07 08:19 PM CTR - Item 14 (Identification)
hawkfan Offline
Member
Joined: Feb 2006
Posts: 83
I thought if a joint owner deposits money into the account, you had to fill out a Section A on both owners (even if only one present). I know you have to, but I am getting hung up on the identification box instruction. Item 14 on the CTR instructions say - If the transaction is conducted by an individual on behalf of another individual not present or on behalf of any entity, enter N/A in Item 14. This would lead me to believe you have to fill out a Section A on the non-present owner, but not Item 14 (identification). Am I missing something? I was originally under the impression you had to fill out Item 14 even if they weren't there.

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BSA/AML/CIP/OFAC Forum
#756369 - 06/19/07 09:12 PM Re: CTR - Item 14 (Identification) hawkfan
GLKS Offline
Gold Star
Joined: Nov 2006
Posts: 344
I have been under the impression that you would be able to use the ID info you have collected from CIP (if available), or make a reasonable effort to obtain that ID info, but it is appropriate to use N/A for a benficiary who is not present if you are not able to collect that information.

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