$0 CTRs: Status Update

According to Pam Johnson, Associate Director, Office of Financial Institutions Policy, FinCEN, approximately 4200 $0 CTRs have been filed under the interim exemption procedure. These "Phase I" CTRs are evenly split between government entities and publicly traded companies. The new procedure has not produced the reduction in CTR filings that FinCEN had hoped for.

FinCEN wants to go to a final rule on Phase I "fairly soon", and will propose Phase II at the same time. The next set of rules will deal with exempting franchise businesses.

The goal of these new rules is to reduce the number of CTR filings. FinCen therefore is encouraging banks to continue to file $0 CTRs even though the time period specified by the interim rule has expired. Johnson said the final Phase I rule will clarify that banks should file a $0 CTR any time within 30 days from the last CTR.

Copyright © 1997 Compliance Action. Originally appeared in Compliance Action, Vol. 2, No. 7, 6/97