New CTR Business Identification line 20

The instructions for line 20 state to "enter the information used to identify the individual or entity recorded in item 4." Wondering how others are completing this section for entities? One of the items that we collect for identifying our business clients is the Certificate of Authority to Transact Business from the Secretary of State's website. If this is being used, would you then enter the Corporate Charter Number listed on this document in the number field or are you leaving those fields blank? Thank you in advance for your guidance.

You're on the right track. Note that when you click "other" that you will open a 50 character field; you can't be too wordy. Also, be careful that your abbreviations would make sense to someone from a different state. Maybe:

SOS Cert. of Authority Dtd. XX/XX/XX

You can identify the issuing state in the following entry. Internally, I suggest you homogenize your descriptions so multiple BSA forms filed on behalf of the same customer say the same thing.

If you use the SOS Cert. of Authority, what is the number you use? The filing number from the state's site? Also, in the business I'm looking at the jurisdiction is not the same as my state (issuing the authority). I believe that what is listed in the jurisdiction is where they are headquartered. The state code I would use is my state issuing the SOS Cert. of Authority correct?

Whether the document establishing existence has a number or just a date varies from state to state. Use whichever is used in the state where the entity is organized.

More useless grist for the mill I guess. Filing a CTR is now becoming more complicated than filing the average 1040 tax return.

We do the same as above, I do check to see if we have the actual articles on file, I generally list "Articles of Organization" (eg.)in other and use the number assigned to it by the SOS.

(The number assigned to it) Are you referring to the Charter Number?

Is it required to on this new form to put the identification of the business?

Yes. Use whatever document references you used under CIP

By the way, this is a "critical" field. If using FinCEN BSA E-Filing system, leaving it blank will stop the submission.

Al