Answer:
The length of the customer's relationship with your institution is not a factor. The instructions for the CTR have an explicit requirement for documentary verification of identity. While there is an old administrative ruling that says you can reduce identification requirements for the elderly or disabled, that would have required acting in advance to amend your BSA policy. Moreover, you would only have been allowed to reduce ID requirements, not eliminate them.
Most, if not all, states offer state ID cards which are neither difficult (nor expensive) to obtain and would be useful to your customer in other circumstances. You should encourage the customer to obtain one and get the information back to you prior to the CTR filing date. Either way, the CTR should be filed on time. If the ID information is obtained later an amendment can be filed.
In simpler times, both the Treasury and the FDIC recommended that a bank should decline a transaction for which identification is unavailable. In the current environment, I would expect an examiner to cite your bank for a violation of law in your next on-site examination. In my opinion, taking a transaction which is clearly reportable without obtaining the identification is indefensible. It does not make a difference who was on the other side of the counter.
First published on BankersOnline.com 5/08/06
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