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#2301343 - 09/05/24 09:11 PM CTR Person Involved Identification
Quarters of Change Offline
Junior Member
Joined: Sep 2024
Posts: 26
I am filing my first CTR and am running into a problem with the joint on the account.
The CTR currently has the person conducting transaction on own behalf, whose information we have, since they were in the bank to make the deposit.
However, the person on whose behalf transaction was conducted is the joint on the account who was not present at the time of the deposit.

For the person on whose behalf transaction was conducted, in Part I Person Involved in Transactions, *20 “Form of ID used to verify identity” -
We have their account opening documents with their SSN and drivers license – however, the joint's drivers license expired prior to the deposit in the account.

What is my best option here?
It didn’t feel right selecting the “Unknown” box, considering we have all of the joint's information and know this is the customer.
It also doesn’t seem right to enter an expired DL.

Should I select “Other” and enter “Account Opening Documents” for the form of identification used to verify identity, considering that’s where we got the SSN?

I’m not even sure if this is the right way to go about documenting the joint benefitting from the deposit. How are other’s documenting the verification of identity with joints who are not present during a deposit?
Am I explaining my issue in an easy way to understand? Lol
Thanks for any help!

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#2301346 - 09/05/24 09:43 PM Re: CTR Person Involved Identification Quarters of Change
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,899
Illinois
Welcome to BankersOnline.

Note that there is no place on the CTR for an expiration date and you are not required to reverify an individual's identity. You select "Driver's License" input country/state of issuance, as applicable, and the driver's license number excluding any dashes or spaces. The fact that it's expired is not relevant to filing the CTR.
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#2301372 - 09/06/24 12:56 PM Re: CTR Person Involved Identification BrianC
Quarters of Change Offline
Junior Member
Joined: Sep 2024
Posts: 26
Sounds easy enough - Thanks for the fast answer, Brian!

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#2301503 - 09/10/24 07:10 PM Re: CTR Person Involved Identification Quarters of Change
John_Burnett Offline
Platinum Poster
John_Burnett
Joined: Feb 2013
Posts: 522
Cape Cod
Put another way -- A person's identity doesn't change when their driver's license expires. But Brian's answer is the best way to look at your question.
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#2301504 - 09/10/24 07:16 PM Re: CTR Person Involved Identification Quarters of Change
John_Burnett Offline
Platinum Poster
John_Burnett
Joined: Feb 2013
Posts: 522
Cape Cod
Let's take it one step further. Same joint account, but it was opened before October 1, 2003, and you don't have an SSN or identity source information on the other joint owner, because there was no regulatory requirement to get it. You would still report the other owner as a person on whose behalf the transaction was conducted, but when it comes to his/her SSN and other ID info -- even DOB -- if the conductor of the transaction doesn't have it or you simply didn't think to ask the conductor -- you check "unknown."
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