I have 2 questions with regards to properly completing CTRs and have been waiting over a week for a response from DCC. Perhaps someone could share their expertise.

1-Is it ok to fill in None in box 19(SSN)Sec.B if there is no other individual conducting the transaction? We are in process to switch to an automated system that prefills this box.

2-If you have no information which would require page2 to print, it is necessary to print it? Again this automated system does not print page2 if there is no additional information.

I think your software is making the intelligent choice in both cases. Don't hesitate to ask your vendor about how it came to make certain decisions or ask for the name of a long term user who may be able to give you some insight.

While questions regarding forms completion should fall to the IRS, FinCEN operates a Helpline which you can reach at (800) 949-2732.

Not that you asked for it, but you opened the door, so here's the relevant paragraph from the comment letter I filed on the request for reduction in the regulatory burden:

*Calls to the IRS Detroit Computing Center Hotline, 1-800-800-2877 should be answered or at least callers should receive the courtesy of having messages returned. I have had dozens of anecdotes offered by seminar attendees where they never received a response to the message they left. I have had the same experience. (I’ve had no reports of similar experiences with banks using the FinCEN 800 number. They have also answered or returned my calls promptly.) However, sometimes what a bank needs is simple information regarding form completion or assistance with a backfiling problem on CTRs; that is the Computing Center’s responsibility, not FinCEN’s.

So far, no results.

I'm assuming your first question is about a transaction for which you have checked off "conducted on own behalf" just above Section B. If that is the case, there should not be anything in box 19.

If you have nothing for page 2, it's OK not to print it.

Yes, it would be conducted on own behalf. I have asked the software company and they have not responded yet either. Unfortunatly I cannot overide the automated system. It is a AML software to assist in detecting suspecious activity and also assist in prepairing the CTR report. I have read the CTR instructions, over and over and it does not specify.

Thank you, I called FinCEN this morning and am waiting for a reply. I have also asked the vendor, they are researching!! You know how that goes.