Final (!?) CTR Update

Enclosed with this HOTLINE you'll find an actual, reproducible, usable Form 4789, Currency Transaction Report.

Finally!

To go with the new CTR, the Financial Crimes Enforcement Network (FinCEN) published the "GUIDANCE ON THE NEW CURRENCY TRANSACTION REPORT (CTR)". We've read it through pretty carefully. Here are the highlights? No change in the types of financial institutions that have to file a 4789. Casinos and the U.S. Postal Service have their own form. By the 15th calendar day after the date of the transaction, we must file with Detroit "for each deposit, withdrawal, exchange of currency, or other payment or transfer, by, through, or to the financial institution which involves a transaction in currency totaling more than $10,000 in one business day, either at one time, or in multiple transactions."

DO NOT use the revised CTR to report suspicious activity. If the amount is less than $10,000, use a Criminal Referral Form (CRF) until the Suspicious Activity Report(SAR) is finalized. If the amount is over $10,000, file BOTH the CTR and the CRF. We will no longer use the CRF after the SAR becomes final in December.

(NOTE: FYI-Non-Bank Financial Institutions [Check cashers, etc.] don't have a CRF or an SAR. They are to just write "SUSPICIOUS" on the top of the revised CTR.)

Start using the new CTR on October 1, 1995, or as soon after as possible. You are to make a "good faith" effort to get usable forms from IRS (request at (800) 829-3676), so you won't be penalized for using either the old form, or for using the "Advance Copy" form supplied for training. Transition time is until December 31, 1995. (Hint-make copies of the enclosed!)

The same policy also applies to magnetic CTR filers. IRS Detroit issued specs in June. Given that it takes six months to install the specifications, you have until December 31st to get your system up and running with the revised format.

If you file an old CTR that has missing information, before October 1, and that information is not required on the revised CTR-don't file an amended form.

Don't put dashes in your MICR numbers.

The preparer and the approver of the CTR can be the same person.

The signature of the approving official in Item 45 must be an original signature-not pre-printed. In Item 48 you may put the compliance office or other designated department instead of the name of a person.

BIG CHANGE.?You (hopefully) have already noticed that the old Section A is now Section B, and vice versa.

Keep copies of CTRs (paper or electronic) for "at least" five years.

The rest of the information is about multiple transactions, aggregation, specific illustrations, explanations (i.e.-a passport is acceptable identification; "cedular" identification is that issued by Latin American countries and Spain), and background on the CTR (i.e., this is the first time in 25 years that CTRs have reduced the amount of information required).

Copies of the ten page document can be ordered by calling (800) 949-2732, or by accessing the BSA-BBS at (313) 234-1453. It should be on there by the end of September.

Copyright © 1995 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 6, No. 1, 9/95