CTR not on us checks cashed

If a customer is cashing a not on us check over $10,000, do I provide the account # on item #22 or is the account number section would only be completed if they used an account at our bank to withdraw the funds? Thanks for response.

I belive that the account # portion of the CTR is for "on us" account numbers only. Not transit account numbers.

This is one of the questions that was answered by the plain-English instructions on the old (paper) Form 104 CTR. You were clearly told that it applied only to accounts held by the reporting institution involved in the reported transactions.

The instructions for the FinCEN CTR data gathering device (I'm trying not to call it a "form") make no such distinction, but I believe that the intent is to get information on any "on-us" accounts involved so as to trace the report back to the transactions on the bank's records.

If you need a definitive answer, you should contact FinCEN's Help Desk and document what you're told about completing this field. (And please share the info here!)

Only an echo; it was clearly stated on the old form, but it is left to the imagination on the new report.

As a matter of personal opinion, they are only interested in the account numbers of the filing institution. Having an account number on a transit check, but not knowing the bank on which it's drawn would tell them nothing.

I can only add that I think FinCEN would have benefited from a much more thorough user-vetting of their CTR and SAR "forms" and instructions before going live. The initial communication of field names and contents was so complex and had so many new items of information that a lot of people just ignored it. When the new CTR and SAR were finally available for industry testing, there was not enough time (and not enough active participants early on) to get enough feedback on the design or instructions. The result, in my opinion, is a format that is simply not user friendly, with disjointed, confusing and incomplete instructions.

A couple of examples -- there is nowhere in the instructions that tells a bank that it needs to supply information on the branch or office where a transaction took place. The instructions consistently refer to the institution where they took place, but not the "office of the institution" or "branch of the institution." Most bankers were not aware that there are separate RSSD numbers for their individual branch offices. Nowhere in the CTR form or instructions is that hinted at. When reporting a foreign currency transaction involving Euros, the CTR calls for the name of a country rather than the old "EE" code we were told to use for Euros. And how, one might ask, is the bank supposed to know which country issued the euros they are handling? They are fungible in the Eurozone, just as Federal Reserve Notes issued by the various Federal Reserve Banks in the U.S. circulate throughout the country. There is no indication on the euro notes (unlike their coinage) that clearly says where a note is issued (there is a letter code at the start of the serial number (just like our FR notes used to have) that identifies the country. Or is it enough to just pick one of the drop down list countries that we know use euros and move on? Again, no instructions.

Can I ask who you are reporting in a CTR for a non-customer cashing an on-us check? I have been questioned on this, and now I'm second guessing myself.

Example:
Customer X wrote a check payable to Non-Customer Y, and Non-Customer Y came in to cash it.

We simply report Non-Customer Y, and only include Customer X account number on the report, correct? We don't report any info on Customer X at all?

You only report information on the person who cashed the check and got the funds which is non-customer Y.

To clarify, Snowmann, the account number is only provided if it relates to the person named in item 4 on the CTR. Since you're reporting on the non-customer only, you don't include the account number of your depositor.

[Note: This is inaccurate. Read the comments that follow. - JB]

On a CTR filing the drop down instructions for Item 21 amount and account number state:

"....Record the account numbers of all accounts involved in the transaction(s)...."

Where does it say that you only include the account number if it relates to the person listed in Item 4?

It doesn't say that.

John is extrapolating from his earlier observations that they only want the account number if the filing bank holds the account.

But Snowmann's post was about a non customer cashing an on-us check so I would enter the account number of the on-us check on the CTR as Dani indicated.

Okay...the account number of the filing institution is what goes on the form.

Whew! Glad you clarified that. We always include the on-us account number when a non-customer cashes a check.

Point conceded. I was looking bleary-eyed at the form, and thought the reference to Item 4 applied to the amount and the account number. It does not. It only applies to the amount. Sorry for the confusion.

Came here from https://www.bankersonline.com/forum/ubbthreads.php/topics/2184225#Post2184225 -- reviving dead threads. We've been filing like JB originally stated, like the old directions used to say. I've gotten calls from the IRS on prior filings. The assumption by the IRS person was that the account number listed was the account owned by the subject. In our case it was, because that (was) the only time we put account numbers there, was for accounts owned/utilized by the subject. If a non-customer cashed an on us check, we didn't list an account number.

Crud, its hard to keep all these little tweaks straight. Especially when it looks like its an oversight.

Reviving dead thread again.

So when a customer comes in and cashes a check from a 3rd party, are you guys or are you guys not entering the 3rd party's account number from the check on line #22? I have always followed the pop-up direction which says only record lines 21 and 22 if the transaction involved an account at your own institution.

Only if it is an onus check from the filing institution.

Not entering as the account does not belong to the bank.

I'll add to the chorus here. In-house account numbers ONLY.

If the instructions aren't clear enough, ask yourself what good it would be if somebody gave you a house number, but not the street it was on as your directions to the party?

What is the value of law enforcement receiving an account number if they have no idea what bank the check was drawn on?

Own bank account numbers only.

Agreed. Having said that, I attended a 2-day BSA school in September where the instructor indicated otherwise. He said the requirement changed with the new filing instructions, reiterating how this had flip-flopped back and forth over the years. I have not been including not-on us account number info on my CTRs; guess I've been dreading it...because I don't believe it lends any value. Glad to know there is a different opinion on this subject.

There has never been a flip flop in the instructions on this issue. Find a new provider.

The "roll-over" instructions in the form clearly say "account involved at the financial institution where the transaction(s) occurred."

Jumping in on this.....if we have our customer A cash a check drawn on our customer B's account, we would then include the account number on the form, correct?

Yes, you would.

Related question- is it a withdrawal or Negotiable instrument?

If it's a check, select "negotiable instrument"

"Withdrawal" is used if the withdrawal is made with a non-negotiable withdrawal order such as a counter withdrawal.

This recently came up for me in my new job. While reviewing CTRs I noted that there was an on-us check cashed. It was written by Dad to Son. Son came in and cashed it. This is done several times per month. It was always my belief--and my previous banks never had an exam or audit issue around this-- that the account number would be recorded since it's an on-us check. Doesn't matter if Son is a customer or not. (If it's a transit check, no account number.) Lo and behold, it would appear my new bank has not been doing it that way. Since the only clear instructions I can find are an FIL from 1995, I contacted FinCEN to ask and haven't heard back. I'm not anticipating them telling me anything different from the FIL; however, one never knows, as they seem to tell one bank one thing and another bank something different (based on my interactions with them through three different banks).

Just refer them to the CTR electronic filing instructions.

22. Cash out amount for individual or entity listed in item 4
a. Acct. number(s) included in item 22

Item 22 Cash out amount: Enter the total cash out amount denominated in U.S. Dollars for the person recorded in Item 4. This amount cannot be greater than the amount in Item 27 “Total Cash Out" Record the account numbers of all accounts involved in the transaction(s). See General Instructions 12 and 13 for additional instructions on entering account numbers and amounts.