*When you register for this webinar you will receive (1) a comprehensive manual with FinCEN’s general instructions on CTRs, exemptions, FAQs, and much more, and (2) a document that includes examples of multiple currency transactions over $10,000 and explanations as to why these transactions should be aggregated or considered separately.
When it comes to filing FinCEN's new CTR many questions arise:
= How do I correct/amend a prior CTR filing via the BSA E-Filing System if I do not have the prior DCN/BSA ID?
= I'm filing the FinCEN CTR on an entity; however, the selections in Item 2a-2c all reference a person. What selection would I choose when filing on an entity?
= Should we aggregate "multiple transactions"? What is the proper way to complete a CTR on transactions involving multiple business entities?
= When we round the amounts on the FinCEN CTR, the total in Item 25/27 differs from that in Item 21/22 (because of rounding). Is this acceptable?
By the end of this session, you and your employees will know the answers to these technical questions, as well as information on many other aspects of the new CTR form.
Under the Bank Secrecy Act (BSA), your bank or credit union is required to electronically file a FinCEN CTR for each transaction in currency—e.g., deposit, withdrawal, exchange, or other payment of transfer—totaling more than $10,000.
Your institution is responsible for determining when multiple currency transactions totaling more than $10,000 during any business day by (or on behalf of!) the same person should by handled as a single transaction. After these internal control systems aggregate currency transactions throughout your bank, your institution is required to appropriately report currency transactions subject to the BSA requirement.
In this program, we will review the data elements and the report line-by-line to ensure you understand the entire form. We will pay close attention to those fields that are marked as "critical" for technical filing purposes. We will discuss how to proceed if your institution does not have enough knowledge about the transaction to provide the information requested in one of the fields.
= Who? What? When? Where? Why? We Cover Questions, Including: Who is Required to and Responsible for Filing a CTR? Under What Circumstances Must a CTR Be Filed? By What Date Must the CTR Filed? Where or With Whom Is the CTR Filed? What Rules or Laws Regulate CTRs?
= Handling Multiple Transactions for One Person. Understand When To Treat Transactions as Individual or Separate Occurrences for CTR Purposes. Determine if Businesses are Operating Separately or Independently of Their Common Owner. Decide if Separate Transactions Should be Aggregated.
= Review Acceptable Forms of Identification for Transactions. Learn Whether Documents Previously Used to Verify an Individual's Identity May Be Acceptable. Learn If a Form of Identity is Required for an Entity.
= Types of Transactions Subject to Reporting Requirements Individually or By Aggregation. These Include Denomination Exchanges, IRAs, Loan Payments, ATM Transactions, Etc.
= Completing CTR for Businesses. Discover the Differences in Filing a CTR for a Sole Proprietor, LLCs, and Joint Accounts.
= Instructor-Led Guide Through Completing the FinCen Form CTR. Review Three Key Sections of the CTR. Review Critical Data Fields.
= NAICS Codes. Explore the Purpose of These Codes & How They Are Used in CTRs.
= Using the FinCEN Directed Back Filing Box
= Exempt Persons. Discuss Which Groups Qualify as Exempt Persons Under the BSA.
= Examples of a Variety of CTRs
= RSSD Number. Locate Your Branch's RSSD Number
Who Should Attend?
This informative session is deisgned for:
- Teller Managers
- Branch Operations
- Deposit Services
- New Accounts
- BSA personnel