Answer:
If you don’t have the information on file, you are not required to obtain it to complete the CTR filing, and we do not recommend that you ask for it. However, if you do have the information (e.g., you obtain it as part of the new account process and it is available in your customer database), you are required to include the information in the CTR filing. You should not complete item 7 based on observation or based on the individual’s name.
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