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#865416 - 12/04/07 10:02 AM Date of Birth on CTR
Jeroen Dekker Offline
New Poster
Joined: Dec 2006
Posts: 11
Is Date of Birth (Item 8, Item 24) mandatory in the CTR? Or can it just be left empty, if we don't have it on file?


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#865417 - 12/04/07 10:54 AM Re: Date of Birth on CTR Jeroen Dekker
MagicCity Offline

Power Poster
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
You should attempt to get it from the customer.

You then need to document why you don't have it and show what steps were taken to prevent it from happening again.

Your problem is not that you don't have it in file.
The problem is that the teller did not ask the customer for the required information at the time of transaction.
(Unless of course, the monies came through the ATM and the customer is pre 2003).

Whichever it is, just document it well how it happened and what you have done to prevent it from happening in the future.

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#865428 - 12/04/07 12:38 PM Re: Date of Birth on CTR MagicCity
Jeroen Dekker Offline
New Poster
Joined: Dec 2006
Posts: 11
Ok, thanks. But process improvements aside, will DCC (in the technical sense) accept or reject a CTR with a blank DoB field? Is blank even the way to go, or should we put "NONE" like we do with the SSN/EIN fields if we don't have them?

And, is the answer different for paper CTR filing and electronic filing? The Magnetic Media Filing specs label DoB and most other fields as Required, and even have error codes. The Form 104 specs are inconclusive.

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#865460 - 12/04/07 02:05 PM Re: Date of Birth on CTR Jeroen Dekker
banker1976 Offline
Gold Star
Joined: Nov 2005
Posts: 344
We file electronically and any blank boxes (i.e. date of birth), we will receive an "acknowledgment error", meaning the CTR filed has been acknowledged but there is an error on the CTR. If we have missing info and are going to file anyway (such as filing without a date of birth) we complete the fill in version on FinCEN's website and then type in (using a typewriter) "not available" in the date of birth box and mail in the form. We haven't had the fill-in CTR's returned when there's at least something typed in the box to reflect the date of birth isn't available (but on the electronic CTR, the field only accepts numbers).

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#865724 - 12/04/07 04:53 PM Re: Date of Birth on CTR banker1976
WonderWoman Offline
Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
I have gotten CTRs returned from DCC if the DOB was wrong (in the future) or missing.

I was under the impression all of that information is required to be gathered before the transaction is completed or you may have a BSA Violation on your hands ...
My opinions are my own, and not that of my employer.

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#865909 - 12/04/07 06:38 PM Re: Date of Birth on CTR WonderWoman
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
Well, there is specific guidance that permits you to use "Not available" (or the electronic equivalent) if a party listed in Section A is not present and you cannot obtain the information.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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