We have a main office and five branches. We have always used our main office address for CTR filings (and recently the RSSD for the main office). I became aware today that each branch has its own RSSD number (thanks to your BOL Daily Briefing)Should we start using the individual branch address and unique RSSD number, based on where the transaction took place for CTR filing? What if it has multiple transactions and multiple locations?
Suspected Money Laundering in the Residential Real Estate Industry: An Assessment Based Upon Suspicious Activity Report Filing Analysis
FinCEN conducted an assessment of SAR reports on money laundering involving the residential real estate industry.
We are taking as security a condo unit in a residential structure. However, the unit is not used as a dwelling. It has a commercial purpose, such as, a doctor's office or a showroom or as a model. Would this loan be HMDA-reportable?
A question about CTR exemptions. We have a customer who owns a bowling alley. He has the bowling lanes, the pro shop, the snack bar and a children's party room organized as four separate businesses, each with its own tax ID number. Invariably, deposits are made for all the businesses at the same time, so they are aggregated and reported on a CTR when the cash amounts exceed the 10K threshold as the same individual makes all the deposits. Is it possible to exempt these businesses even though individually none of them ever exceeds the 10K reporting threshold? I assume that we would have to file a separate exemption form for each business.
Does the BSA regulation require testing employees? A few years ago one of our examiners said we should incorporate testing into our training. I can't find this in the reg.