FinCEN changing CTR filing instructions

FinCEN has reportedly notified discrete and batch CTR filers of revised instructions for completing item 2 of the CTR when a person conducts multiple transactions and more than one item 2 option applies to the conductor.

If more than one Item 2 option applies to a Part I person, a separate Part I section will be prepared on that person for each Item 2 option. For example, if the Part I person conducted a $5,000 deposit into their personal account and a separate $7,000 deposit into the account of another person/entity, there will be one Part I on that person reporting option 2a on the personal deposit with that amount and account number in Item 21 “Cash in amount”. There will be a second Part I on that person reporting option 2b on the person/entity account transaction with that amount and account number in Item 21.

According to our source, an October 2 post in a thread in BankersOnline's BSA/AML/CIP/OFAC discussion forum, the change is being made because CTRs have been rejected without a 2c owner record and users of the CTR data are unable to fully understand the transactions being reported using current instructions. No changes are being made to the filing form (other than an instruction update for item 2). FinCEN has proposed a target date for updating its batch filing of October 1, 2019, with a mandatory effective date of February 1, 2020.