A customer cashed a $10,000 check payable to himself from his business account, and within that same weekend withdrew $200 from from his personal account at an ATM in another state. I do not have enough information on the location of the ATM other than the city and state.

Can I set the location to Unknown?
If not, how am I supposed to locate the ATM?

We called FinCEN about this same situation and were told if we do not have the full address of the location (City, State, Country, Zip Code), that we could use our home bank office as the location. However, we were to document that per our system, the full address could not be identified. If we know part of the address, we are documenting that internally.

Once again, FinCEN is making stuff up on the fly to address situations not contemplated in the design of its reporting requirements.

Previous thread

Thanks for sharing. As John implies, the "answer" puts a band-aid over a question that should have been addressed when the data entry device was designed. However, I'm increasingly accepting of those types of responses.

Implementing one silly option coined by FinCEN is easier than implementing the multiple silly options coined by examiners and other third party reviewers.

I left a message with FINCEN this morning. Hopefully they will respond soon!

Received voicemail from FINCEN.

If the ATM is non-proprietary, and we have no additional information other than the city and state of the ATM, we will need to list an additional part III with our institution's information given the fact that we don't have any additional information other than the city and state of the foreign ATM.

So it sounds like I need to have two Part III sheets - 1 for the branch where the first transaction took place, and 1 with my institution for the non-proprietary ATM, but marking location as "Unknown".

However, this morning my E-Banking department was able to spit out a report of the specific location of the ATM, so now I can amend the CTR to provide the location of the non-proprietary ATM.

I just want to conclude by saying, this is ridiculous.

Thank you.

To all others: You need to submit the question to the Helpline yourself. I cringe every time a banker says: "Well another banker told me the Helpline said 'Thus and so' so that's what we do." Any unsupported guidance the Helpline offers is helpful to the person who got it and puts a memo in the file, but it's just a bunch of words to everyone else.