We all know that we are required to file a CTR with FinCEN for each deposit, withdrawal, exchange of currency, or other payment or transfer, by, through, or to our financial institution which involves a transaction in currency of more than $10,000 (Wow! That’s a mouthful). This shouldn’t be too difficult to do, right? But as frequent filers know, CTRs can be quite tricky because there are so many different scenarios.

But, just when we think we have it down, FinCEN decided to shake it up and change things. On October 1, 2019, FinCEN issued an important notice meant to fix rejected CTRs and help confused users of BSA data. Specifically, the change affected the way Financial Institutions file CTRs when an individual subject has multiple Part I, Item 2 roles.

 

PREVIOUS INSTRUCTIONS

If more than one Item 2 option applied to a person involved in the transaction(s), only one Part I on that person was completed, with only one entry in Item 2.

If options 2a, 2b, and 2c or options 2a and 2b or options 2a and 2c applied to the person conducting the transaction, option 2a would be selected. If both 2b and 2c applied, 2b would have been selected.

 

Example

On the same business day, Wayne deposited $4,000 in cash into his personal account and a separate $9,000 cash deposit into the account of Kelly.

Previous Filing Requirement:

Complete a Part I for Wayne and select box 2a. Record $13,000 cash received in box 21.

Complete a Part I for Kelly and select box 2c.  Record $9,000 cash received in box 21.

 

NEW INSTRUCTIONS

Item 2: Select option 2a if the person recorded in Part I conducted the transaction(s) on his or her own behalf. Select option 2b if the person recorded in Part I conducted the transaction(s) on behalf of another person. Options 2a and 2b cannot be selected if box 4b‚ “If entity” is checked. Select option 2c if the transaction was conducted by another for the person recorded in Part I. 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.

 

Example

On the same business day, Wayne deposited $4,000 in cash into his personal account and a separate $9,000 cash deposit into the account of Kelly.

New Filing Requirement:

Complete a Part I for Wayne and select box 2a. Record $4,000 cash received in box 21.

Complete ANOTHER Part I for Wayne and select box 2b. Record $9,000 cash received in box 21.

Complete a Part I for Kelly and select box 2c.  Record $9,000 cash received in box 21.

 

Still Confused?

More information regarding this change can be found at: https://bsaefiling.fincen.treas.gov/docs/XMLUserGuide_FinCENCTR.pdf

If you have any questions, contact the BSA E—Filing Help Desk. You can open a support ticket at: https://bsaefiling1.fincen.treas.gov/HelpTicketForm