CTR Collection of Gender

What is the correct way to collect gender for CTR purposes? Should you ask the individual, take it from the ID, or base it off of visual observation?

Select the option “Male” or “Female” if the individual’s gender is known. Select the option “Unknown” if the individual’s gender is unknown. Item 7 does not create an obligation for a financial institution to collect this data when such collection would be in conflict with the financial institution’s obligations under any other federal law.

Not sure if there is any specific required way to make that determination - just that if it is known you have to report it.

Other than for HMDA or ECOA purposes how would it be known unless you ask the individual, take it from the ID, or base it off of visual observation?

i think you just answered your own question, although basing off observation could certain be fraught with incorrectness

I would never recommend asking the individual (how awkward would THAT be?) or basing it on a visual observation for the purpose of completing that item on a CTR.

So I guess that only leaves using entering the gender from the DL correct?

If you don't already have the gender info in your records, you don't need to obtain it. The fact that it is on the DL that the individuals shows you for ID to be recording in item 20 does not mean you must record the gender annotation from the DL for item 7.

But if you do record the gender, it now becomes part of the bank's records and will have to be included on each CTR you file with that individual included on a Part I section.

One other thing: Many states allow the gender marker "X" to appear on DLs for individuals who don't wish to be identified as male or female. Since the only options accepted in CTR item 7 are "M," "F," and "Unknown," you'd select "Unknown" if the DL shows Gender X.

Is gender a critical field on the CTR? It's been so long since I looked at the form.

No, it is not marked with an asterisk. But remember, FinCEN instructions indicate that the critical fields are those that can trigger a rejection of the filing if they are not completed. FinCEN expects all fields to be completed. For gender, your options are M, F, and unknown. The default should be Unknown if you don't have the information.