We were recently cited for allowing our tellers to use the term "retired" as an occupation when completing a CTR. I recently attended a BSA seminar where the speaker noted that this is acceptable in describing the individuals occupation. I also have a bsa manual we have purchased that says the same thing.

I am drafting my response to the audit findings and wanted to rebutt this finding so I went to FinCENs website to try and find some Q&A that might back my position but I can't find any "official" statement that says it is acceptable to use "retired". Does anyone know where I can get official comments relating to the use of "retired" as an occupation.

The auditors want the tellers to state "retired fireman", "retired chef", etc.... I've been told that is not necessary.

Thanks.

http://www.bankersonline.com/ubbthreads/...true#Post269344

This should be helpful to you.

K

Keep in mind that this information crosses over to AML purposes. Knowing if someone is a retired hedge fund manager or a retired librarian helps you to understand if their monetary transactions make sense. It is all part of knowing/understanding your customer.

This is an area that examiners always go to, because they know they can find employment titles not descriptive enough, and therefore write you up for it.
I think it is better to get the most description you can, so Retired, Unemployed, and especially Self Employed cannot be used by themselves but must always have more information.
IMHO.