Our internal audit staff found "isolated" instances of our bank using unemployed and disabled for occupations on CTRs. The one instance they included for disabled is an individual who has been disabled since birth, so there is no former occupation. They are including these as audit findings. I've challenged them to show me where the regulators or any other government agency has stated that these descriptions are not allowed. So far, they haven't been able to, won't listen to reason from our attorneys and appear to be writing federal policy on their own.

Any ideas?

I think you have a good argument for the disabled description in this specific case, since the customer has been disabled for life.

You might have a harder time if you typically just use "unemployed" and do not have a policy of inquiring about their past occupation. In situations where the customer is not present, it could be acceptable, but on face to face transactions, this question should be asked of the customer.

You might want to check out the instructions on the latest Form 104:

Item 13. Occupation, profession, or business. If known, identify the occupation, profession or business that best describes the individual or entity in Part I (e.g., attorney, car dealer, carpenter, doctor, farmer, plumber, truck driver, etc.). Do not use nondescript terms such as businessman, merchant, store owner (unless store’s name is provided), or self employed. If unemployed, or retired are used enter the regular or former occupation if known.

I agree with Randy on both counts.

We've actually had CTR's sent back from the IRS for using "unemployed" and also cited by our examiners.