What Identification should be used on CTR filing?

What is the proper identification that should be used when filing a CTR or SAR on an entity if you have multiple pieces of identification?

Pick one

So there isn't one that should be used before the other?

For an entity, how many can their be? It usually is something that ties back to the State in which they are registered.

Regarding a SAR, this topic came up in a seminar with Ken yesterday and he told us that FinCEN wants every form of ID included that the bank has on file for the subject in question.

Every piece. Please list what you consider id for an entity.

Depends on business structure, but could include (not limited to) Articles of Organization, Articles of Incorporation, Certificate of Good Standing/Existence, Business License, etc. At my previous bank, we required two forms of identification for CIP on entities and the list was pretty extensive, so we generally had at least two identifying documents on file for any entity.

Well you would pick one for either a CTR or SAR. If you thought the other id was important to law enforcement, those would be included in the narrative.

Unless the documents have government issued numbers associated with them, they are not id.

The SAR does have + and - buttons to add extra forms of subject identification.

I never notice that, charlied. I haven't had to use it yet, but that is good to know. Its hard to believe how many little things I never see until one day it jumps out at me.

I hadn't noticed it either, until Ken pointed it out. I blame it on the complexity of BSA. There are just too many details to keep track of. That's why I am thankful for places like this.

Our auditors bought that to our attention in a recent audit and we use one item such as articles of organization and our examiners were okay with that.

Since the new CTR and SAR formats went into effect we only use 1 form of ID for persons and businesses and there have been no comments from auditors or examiners.

we only use 1 form of ID for persons and businesses and there have been no comments from auditors or examiners.

That is because they don't know. I have to admit that even slipped by me. However, if you have more than one ID in file, you would be required to provide it in the SAR (as apparently Ken has indicated) in order for the SAR to contain complete and accurate information.

Same here - brought up by an auditor - we started using the Articles number filed with the state.

Just a suggestion. It is almost axiomatic that a corporation will have "articles of incorporation," an LLC "articles of organization" and a partnership a "partnership agreement" (yes, I know some do not). However that response is like saying an individual had a "drivers license," but not noting the number.

This comes from me, not FinCEN, but I suggest that when you are saying the entity had the document upon which its existence depends, you add the date; e.g. Articles of Incorporation DTD XX/XX/XX. It indicates you actually saw them. The "number" box might confirm that, but there will be none for entities that have no state registration; e.g. general partnerships, estates, trusts, etc.

That would make logical sense Ken ... but as we know ... examiners don't always have that ...

Has FinCEN updated any FAQs regarding this? It seems to be a new hot topic for auditors to pick on.