This is from FinCEN's 1995 guidance - is this still accurate?

C. Currency Transaction Report (CTR) & Designation of Exempt Person (DEP) Questions
C1.Q: Is "retired" an acceptable occupation to enter on the CTR form?
C1.A: Guidance issued September 1995 by FinCEN advises that “homemaker”, “retired”, or
“unemployed” are acceptable as occupation descriptions, but that financial institutions should
attempt to get information that is more specific, and pay particular attention to customers with
such non-specific occupations who continually make large cash deposits. In addition, the
occupation “self-employed” is not acceptable without additional information as it is too nonspecific.

I've read here multiple different posts stating that the request is to note what they are retired from, not just that they are retired.

I have it written in policy that if the customer is of retirement age, then retired is acceptable.

The regulators have been fine with it.


The whole point really is to be able to match the cash activity with the occupation for "reasonableness".

And for my area anyways, retirees stashing cash in their mattresses until a large forest fire breaks out so they rush it all into the bank, is very very common.

May be regional, or agency specific, but a lot of examiners (and me) want to know retired from what since that can provide insght into why the person has available cash. (I was going to say available fundss, but it looked like I was crossing over to Reg CC!)

When would a retired person have access to a large amount of cash where their former occupation would explain it away? They aren't working so .....

& anyone, over time, can save a lot of cash - I've seen hundreds of thousands brought in garbage bags from kids cleaning out grandpas house.

Yes, people can save and inherit money, and win it, steal it and a thousand other things, but a retired Wall Street investment banker would conceivably be expected to have more funds than a retired fast food worker. It is just one more piece of info but it is helpful info.

No. More recent instructions are a tad more specific. The instructions for the Form 112, the FinCEN CTR, are pretty clear:

Do not use non-descriptive items such as businessman, merchant, retailer, retired, or self-employed. If words like self-employed, unemployed, or retired are used, add the current or former profession if known (e.g. self-employed building contractor, retired teacher, or unemployed carpenter).

While the "if known" should give the filer the opportunity to say "We didn't know," disregard it. Beat the former occupation out of them if you have to, fill in the box, then go do something that makes a difference.

This is one of the oldest, most worthless debates on CTR completion; I plead with banks to get the get the prior occupation only so they do not have to waste any time discussing it.

If the person tells you that he is an unemployed brain surgeon that does not tell you where the money came from - it tells you where the money did not come from. There are a few thousand other vocations that may account for the cash, but not brain surgery because he does not do that anymore. Besides, I would say a cowboy or a day laborer is more likely to get paid in cash than a brain surgeon; if an employed brain surgeon has 10K+ in currency, it did not come from his employment. So, when he is unemployed...

True Ken, unless you're using an unlicensed brain surgeon!

I always found it took the bank ten seconds to ask, and in my experience ten weeks to argue about it.

First hand experience, not only our examination team but our auditors always check for this on CTRs.

Our fraud team loves having this extra piece of information. Knowing what they are retired from can give you insights into their behavior. A retired building contractor might do small woodworking jobs for cash. A retired nurse might do in-home caretaking for cash.

Just do it.