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Instructions On How to Complete Amended CTRs

Answered by: 
Ken Golliher

Question: 
I just received two amended CTRs I had filed on 9.11.11 before they changed the rules for amended CTRS. At the time I attached a amended form with just the information that was incorrect on the original CTR. The rule changed on 10.31.11 stating that you made out a complete new CTR indicate it as amends prior report. So now it is 2013 and I have two CTRs to try to efile and can't find any instructions anywhere on how to do this. I tried to file FinCen CTR but it asks for a DOC # 14 numbers long; which of course I do not have. Do you have any idea where to find the documentation to show how to do this?
Answer: 

From the instructions to the FinCEN CTR:

Enter all zeros if the prior report DCN or BSA ID is unknown, for example when the prior report was a paper filing.

As a caution to others, I think any reviewer's presumption will be that this is for a form filed on paper as was the case here. My observation would be that the DCN from an electronically filed form is subject to a 5 year record retention requirement and the filer is obligated to have it; this is not a "get out of jail free" card.

First published on BankersOnline.com 4/8/13

First published on 04/08/2013

Filed under: 
Compliance
Filed under compliance as: 
FinCEN
ID
IT
Record Retention

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