I've spoken with other bankers who had the same problem. They were told by the Helpdesk that filing the correction is not necessary, just do it right from now on.

However, that's no good to you when it's you vs. an all powerful field examiner. Make the call yourself and put a memo in the file regarding your conversation. Every anecdote I have heard from bankers is that examiners are not looking at the new reports because they have had no training on them. However, they will begin looking at them on and after April 1 without a doubt.

Thank you and John both.

what if when following the directions to get the RSSD Id you run across listings for branches that are not in existence or have changed locations (but are not listed)? Who should be updating this information and/or how does it get updated?

If you think it's a problem, you might contact the NIC through the "contact us" tab at the bottom of the page, but it's not a BSA issue. FYI, I tried to contact them a couple weeks ago and it was a complete waste of time...

Thank You so much! We have struggled with how/where to find this information.

I guess I thought this might be an issue because we have one branch location listed with an RSSD number that isnt at that physical address anymore but moved slightly down the street. If this branch is used for a CTR reportable transaction am I not supposed to list the RSSD number because it wouldn't match what is listed (physical address) or should I use that close approximation (old address)? I don't want there to be a problem when we get examined for this.

Anyone questioning your choice will be using his or her version of logic, not the instructions. Call the Help Desk, write a memo to file, and go with what they tell you. This isn't something you want to talk about twice...

Thanks Ken for the advice on this.

Has anyone contacted FinCEN for their spin on this?

Ok....so since #39 is not a required field can we just skip the headache and leave it blank?

No. FinCEN expects banks to provide all of the information they can. Examiners and auditors will make certain they do.

Besides:



At some point, just plugging in the RSSD will increase the accuracy of the CTR and shorten its completion time.

If you think that completion of any of these boxes are optional when the information is available, then I think you will have a rude awakening at the next exam.

I just contacted FinCEN regarding this a couple of hours ago and they reassured me that the number they are looking for is the RSSD number that corresponds to the specific branch where the activity occurred.

That's no longer being debated here.

Yes...I guess I knew that but was hoping for the best. This is actually quite minor considering what's going on in the lending side.

Well, I have heard rumblings that the regulators are fully prepared to pull out the $500 per form negligence filing CMPs on banks that don't get this conversion to the new forms correctly.

I want to be a Walmart greeter..

We had always filed paper in the past and in June of last year went with Verafin for AML and report filing. I had never heard of a RSSD number until quite recently. Verafin has rolled out the new version of the CTR and we have been using that for quite a while now. This problem is that they do not have a place for us to put in the branch's RSSD #. They are working on a fix and I am sure plan to have it completed before 03/31/2013. My question is - will I have to back file the CTR's that have already been submitted through Verafin even thought the new form is not required until 04/01/2013?

There's a post above recounting the fact that banks who did not realize how specific the requirement is were told by FinCEN that they did not have to file corrections on prior reports; they were just told to "Go forth and sin no more." My observation is that's only good advice when the bank made its own phone call and can document who they spoke with.

That's a decidedly different circumstance than knowing it's required and not doing it for a period of time yet to be determined. (If your software can't do it correctly, you could file discretly without using the software; there is no issue of impossibility.)

You're going to need to call FinCEN and get their answer to the question.

Thank you.

"This problem is that they do not have a place for us to put in the branch's RSSD #."

My next question would be - what other boxes on the CTR have no provisions to make proper entries??

If we are only showing 20 out of 25 locations in our state, what should we do?

If the branch where the transaction took place has one, use it. If it does not, leave it blank.

FWIW...I left a message at FinCEN with regards to the RSSD numbers. I told them we had been using the BANK RSSD number and not the branch numbers and asked for guidance on how to proceed. I received a voice mail back stating that they have had many calls from banks with the same issue. He stated he is forwarding my message to compliance and sometime in the near future they will issue a statement on how to proceed with the incorrect filings. In the meantime, start filing with individual branch numbers if you have them.

FiServ is our AML provider, and we just installed the update. They pull the main bank RSSD number not the branch RSSD, so we have to go to our Notepad file before we efile and change the script to the branch numbers. This is just until FiServ has a solution, but it will be tedious. Thankfully, we hadn't sent any files yet with the new CTR.