I have a BSA question about Phase I exempt customers. I know that Phase II customers' savings accounts can't be exempted, but what about Phase I customer savings accounts? At my institution we have a government entity but they only hold savings accounts with us. Would they still be considered Phase I exempt in our institution at all? And if so, would we have to perform a yearly review on them?
When the owner of an ATM resides in a state that requires the ATM be registered refuses to register that ATM; do you file a SAR on that customer for failure to provide documentation? If a SAR is required, does the continuous SAR filing rule apply until the customer complies?
Filings on Mortgage Brokers
The new E-Filing form FinCEN CTR form 112 doesn't require us to enter any option in field number 39 (rssd #) should we be entering this information anyway? and if so, do we have to go back and redo all the prior CTRs or wait for them to be returned?
When filing a SAR for insider abuse, should the narrative contain any admissions, denials or conversations HR had with the employee in regards to the alleged activity? Is it required to include that information?
FinCEN conducted an assessment of SAR reports on money laundering involving the residential real estate industry.
By FinCEN Office of Regulatory Policy
If a customer deposits over $10,000.00 into a joint account, how do you fill out the new CTR if only one owner is present? Would you check the person conducting transaction on own behalf box for the owner present, making the deposit? And then check the person on whose behalf transaction was conducted box for the joint owner who was not present?
If a government agency (DEA) sends a representative to purchase an Official Check do we need to get the identifying information on the government representative?
We have an armored car service that is acting as an agent for 3 different area businesses and delivering their deposits to the bank. We know that the transactions are CTR reportable over $10000, as they share the same transactor and that the July 2009 FinCEN Guidance indicates that we would need to gather the transactor's personal detail (not just mark Armored Car), but...Is there anyway to exempt the Armored Car company from CTR reporting? (We can't think of one, but we are looking at 50+ CTRs a year that would need manual merging in our processing system.)