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#2043670 - 10/09/15 07:41 PM amend these CTRS?
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Not sure if we need to amend these:
1.Amount incorrect by $10.00 (we were under by $10,00 on amount of transaction).
2. Part II amount was correct. Re: part I amount, part of the amount was transposed
3. First name spelled incorrectly; the rest of the CTR is correct.

Thanks!

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#2043676 - 10/09/15 07:45 PM Re: amend these CTRS? Trees
John Burnett Offline
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Cape Cod
You should file amended CTRs for each of those. There isn't a "that's good enough for gummit work" option in the CTR instructions.
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#2043690 - 10/09/15 08:23 PM Re: amend these CTRS? Trees
Elwood P. Dowd Offline
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Next to Harvey
The only folks who can say an amendment is unnecessary work at FinCEN. There are no published "close enough" rules.
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#2043900 - 10/13/15 04:23 PM Re: amend these CTRS? Trees
Trees Offline
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Posts: 4,013
Well, that is clear. Thanks folks.

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#2098568 - 09/14/16 09:50 PM Re: amend these CTRS? Trees
CML LHS Offline
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CML LHS
Joined: Oct 2014
Posts: 18
WA
Would a full name versus shortened version be amendment necessary (for example, our customer database says his name is Christopher, but we filed with Chris), or if our customer record for a business does not include the punctuation that the SOS has (ABC, Inc.versus ABC Inc)? I know it would be easiest to amend, but for the future I am curious about training my staff, versus making the changes in our core system so the names always match the SOS if possible.

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#2098594 - 09/15/16 10:07 AM Re: amend these CTRS? CML LHS
Elwood P. Dowd Offline
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Elwood P. Dowd
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Next to Harvey
Quote:
The only folks who can say an amendment is unnecessary work at FinCEN. There are no published "close enough" rules.


A variation in punctuation has no effect on the data provided. I suggest that the name on the account should match that found on the identification and the name on the report should match both.
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#2098787 - 09/15/16 09:53 PM Re: amend these CTRS? Trees
Just Jean Offline
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Joined: Feb 2002
Posts: 582
USA
Would you amend a CTR that is correct as far as it goes but did not include the middle initial of one client?

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#2098788 - 09/15/16 09:54 PM Re: amend these CTRS? Trees
RockChucker, CAMS Offline
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Joined: Jul 2013
Posts: 1,700
The Country
I have too much on my plate to worry about something like that but I am curious what others think.
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#2098795 - 09/16/16 01:37 AM Re: amend these CTRS? Trees
BrianC Offline
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BrianC
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Illinois
Ken's answer above is the only answer that anyone not working for FinCEN can give.
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#2098909 - 09/16/16 05:43 PM Re: amend these CTRS? Trees
Sunshine Lady Offline
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Sunshine Lady
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Posts: 705
I am only answering this because I have had the situation with the middle initial and called FinCEN and was told that I did not have to amend the CTR. Now the flip side of that coin is if you call and get someone different than I talked to you might get another answer. If you call FinCEN, I would document their name, time and date and what was said. If possible, we are able to put notes on our CTRs and if you are able, I would do that.
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#2098926 - 09/16/16 06:00 PM Re: amend these CTRS? Trees
bcompliance Offline
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Joined: Sep 2014
Posts: 1,313
The middle initial is not a required field on the CTR form. If you have it, you should include it. If you did not have it at the time of filing, and then later obtain the middle initial, I would not spend the time to track that and refile because it wasn't available at the time of filing. Just my opinion.
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