When a bank is filing a CTR form via paper or E-Filing, does the suffix (Sr., Jr., III, IV) need to be included on the form or file before sending to FinCEN? If so, where do you enter the suffix?

Thanks

Yes (Jr. and Sr. are not the same person). I believe it is entered as part of the last name (Ex. Doe Jr).

For E-filing:

A. Delete any titles, prefixes, suffixes or other descriptive information such as Mr., Mrs., Dr., Reverend, Partner, or Trustee. Do not delete suffixes which distinguish family members such as Jr., Sr., III or IV. Suffixes should be edited to follow the middle initial (e.g., Doe/John/L Jr).

B. Delete all punctuation (e.g., ‘JR.’ would be submitted as ‘JR’).

Refer to: BSA Electronic Filing Requirements For The Currency Transaction Report (CTR) (FinCEN Form 104) and Designation of Exempt Person (DEP) (FinCEN Form 110)

Hello,

Thanks for your responses. So, should it be entered as part of the last name or middle initial? Is it a requirement by FinCEN? Do you know if a bank will get an error if it is not submitted with the suffix?

When I e-file a CTR, I put "Jr" or "Sr" after the last name. E-filing will not let me enter but 1 letter for the middle initial.

E-filing or your software that you use for e-filing?

The actual e-filing field is 35 characters long and you are required to enter the name of individual conducting the transaction, "last name/first name/middle initial". Left justified and space filled. You must following the Name Editing Conventions shown in my previous post.

Sounds like you need to have a chat with your e-filing software provider.

You would be amazed to the e-filing software providers that don't know the rules. If your audit is not analyzing your actual submission files (not your software reports), there may be other erros.

We had this same problem with the middle initial box using the Adobe form directly from BSA E-Filing. We called the e-filing help desk and they said the only way to enter the suffix was to add it in the Last Name box "maybe" inserting a comma after the last name. Hopefully their next form revision will correct the problem.

I have always entered in the last name box:

John
E
Smith Jr