10/15/2017
I have a SAR filing question, regarding NAICS codes. We have an internal Quality Assurance Department that reviews all SARs filed in our BSA/AML Department. We are being advised to apply NAICS codes based on the type of industry an individual is employed in; For example we have an individual that is employed as a SCHOOL NURSE – I believe the NAICS code should be 6213 “Office of Other Health Practitioners." However, my QA team is suggesting we use NAICS code 611 “Educational Services.”
Other Examples
Anesthesiologist with Conta Costa County we used 6213 “Office of Other Health Practitioners” – my Investigator was told to change this individuals NAICS code to 923 “Public Administration/Administration of Human Resource Programs, because the individual is employed with the County of Conta Costa. Or Accountant for New Beginnings we used 5412 “Accounting, Tax Prep” – my Investigator was told to remove 5412 and instructed to leave the NAICS code field blank because we could not definitively identify what type of business New Beginnings operates. I would greatly appreciate your interpretation or any reference materials like a previous FinCEN FAQ or SAR Activity Review Trends, Tips & Issues that would clarify or address this issue.
08/13/2017
Is there ever a time when an SSI account is over $2000?
08/06/2017
Can a financial institution turn over funds to the minor at majority on a UTMA?
07/23/2017
We have a guardian who wants to put an authorized signer and a POD on a guardianship account. Is this a good practice?
06/18/2017
A new CSR opened an account and let the customer do all kinds of weird things with Pay on Death beneficiary designations that aren’t legal in our state. Now what?
06/04/2017
We have a customer who is a level three lecher. He ogles the female tellers and makes lewd comments about them and to them. Please tell us we can offload him.
05/14/2017
How do you find the guidance that applies when there is no regulation?
04/16/2017
Can a single-member LLC use an SSN?
04/02/2017
Do we have to update our W-8BENs?
12/04/2016
The following Preview Question from a Learning Connect webinar for the 6-21-16 "Currency Transaction Report Annual Training for the Frontline." This does not appear to match the information from the BOL Compliance Q & A "Report $300 Currency Exchange on CTR?" dated 5-13-13. Your thoughts?
P R E V I E W Q U E S T I O N
Q: We had a customer come into the bank and purchase a cashier's check. He brought in $17,750.00 in cash. The cashier's check was made for $17,725.19, he paid a fee of $3.00 and received $21.81 back in cash. The CTR really doesn't give you a place to put the cash back on the cash in side of the sheet. How would you fill out the sheet so it will balance at the bottom?
A: You would only put on the person's page $17,729 (equals the $17,725.19, rounded up, plus the $3.00 fee). Plus on the cash page $17,729 for the Negotiable Instrument purchased and nothing else needs to be listed.