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CTR on Armored Carrier Services for MSBs

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We currently use armored carrier services for our MSB customers when ordering cash. For CTR reporting, we report on "delivery date" Vs "order date". Going forward, we are conducting research and looking to report our CTRs on "pick and pack", which is the date funds are actually removed from our vault, but not delivered to the customer. Would this change be acceptable to the IRS?

Answers to such specialized questions aren't publicly available. I suggest that you contact FinCEN for guidance on the issue, document exactly what you asked, with whom you discussed it, and what the answer was, and then establish a procedure that is consonant with FinCEN's guidance. It is likely that FinCEN will suggest that your procedure be consistently applied and that the CTRs will be capable of being used as "tracer" documents to identify and point to the detailed records of the transactions on your books.

First published on 4/05/10

First published on 04/05/2010

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