Missing non-customer SSN for CTR

Answered by:

Question:

We have a new teller that cashed a $11,500 check for a non-customer. She verified the customers ID and got all the required information for the CTR except for his SSN. We have called the individual and he refuses to give us the SSN. How do I proceed with the CTR and is a SAR necessary?

Answer:

You cannot fail to file the CTR, with or without the SSN. I don't recommend entering "none" in the SSN field, because that would be a misstatement of fact that the individual actually did not have an SSN. Go ahead and file, with a cover letter explaining that the teller failed to obtain the SSN and that the payee of the check refused to provide it after the fact. Include in your letter a summary of your plan to retrain the teller and to ensure that bank policy and procedures are clear on the matter of obtaining the SSN for CTRs. Be prepared to refile the CTR later if it is rejected by the IRS for the missing SSN (sometimes correspondence gets separated from CTRs).

On the SAR question, the check payee appears to have caused the bank to file an incomplete CTR, which is a federal offense. File the SAR if the dollar amount hits the filing threshold.

First published on BankersOnline.com 4/18/11