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New CTR Form Require ID Collection of Entity?

Question: 
In a training last week it was brought to my attention on the new CTR form that it is requiring the ID collection of an entity. In the past this has never been the case and in the FFIEC manual it specifically refers to individuals. FinCEN has said that there is nothing new to the forms except the collection of the new fields. Not in any webinar or documents that we received from FinCEN said anything about identifying document collection of an entity for a CTR. The only thing I have seen regarding this is actually on the form from the help box in the ID field itself. Is this something we have to collect going forward?
Answer: 

Answer by Brian Crow:Since you have to identify business customers as well as consumer customers to meet your CIP requirements, you should already be collecting business identification in the form of articles of incorporations, LLC agreeements, partnership agreements, assumed name certificates, etc. Utilize these identifying documents when completing the new CTR for a business.

Answer: 

Answer by Ken Golliher: The instructions are pretty clear, but I've added emphasis in a couple places:

Item *20 Form of identification: Enter in Item 20 the information used to identify the individual or entity recorded in Item 4. Check box 20b if the identification was a driver's license or state ID, box 20c if the identification was a passport or box 20d if the identification was an alien registration. Check box 20z if a different identification was provided and describe that identification in the "Other" text field. "Other" identification could include such things as an entity's business license or incorporation documents, corporate ID cards, local government ID cards, etc. [Abridged]

As noted, this is information that the CIP regulation required your bank to obtain if the account was opened in the last 9 years. The Form 112 is simply repurposing information you should already have.

The current version of the Examination Manual was published in April, 2010. It is not a reliable resource for anything that has changed since that date.

First published on BankersOnline.com 2/18/13

First published on 02/18/2013

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