Answer:
Answer by Richard Insley: Refuse the transaction. If your account agreement doesn't already spell out the customer's duty to provide information that is required by law, amend your standard agreements.
Answer:
Answer by Jim Bedsole: You may also want to consider whether a SAR filing is warranted based on the refusal to provide the information.
Answer:
Answer by John Burnett: Use forensic methods to search out a street address. Review checks drawn on or deposited to the account to see if one might reveal a street address. Once you've found it, amend the CTR to correct the PO box address you used if you had to in order to make the filing deadline. On a going forward basis, refuse any other reportable transaction unless the customer provides the correct information.
First published on BankersOnline.com 11/12/12
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