CTR Contact Number & Contact Office
In this Compliance Clip (video), Adam explains the requirements for completing the contact number and contact office fields on the CTR. Adam also reviews a few FAQs and explains a common CTR violation.
Video Transcript
The following is a transcript of this video.
This Compliance Clip is going to discuss the CTR contact number and contact office. This is a BSA/AML topic.
The CTR Contact Office has been somewhat of a confusion for some BSA officers or those who complete CTRs. In fact, when I've conducted audits of CTRs, I've found this to be a very common violation. Now, it is very low risk, but it's a technical violation because the FinCEN frequently asked questions specifically address what you're supposed to put in the contact number field and the contact office field. So, for the CTR Contact Office, let's take a look at the frequently asked question from FinCEN and see what it says..
It's actually Frequently Asked Question No. 33 and the question is, “Item 40 now asks for a contact office and not a contact person. What information should be provided in this field?” Great question. I'm glad you asked! So, the answer here from FinCEN, not from me, is that the filing institution needs to enter the name of the office that should be contacted to obtain additional information about the CTR. It is the filing institution's choice as to which office this should be, and in the frequently asked question, they give some examples of what type of office. This could be “Compliance Office”, the “Security Office”, the “BSA Office”, or maybe the “Risk Management Office”. The office may or may not be located at the same location where the activity took place, but that is okay. The bottom line here is you're supposed to be listing the name of an office.
This is something that changed several years ago when we went to the electronic currency transaction reports, because under the legacy CTRs, we had to list the contact person. So we would list “BSA Officer”. What the rule says now with the frequently asked question here explains is that we're not supposed to list “BSA Officer”. We're supposed to list BSA Office or whatever other office you want to list. If you're listing “BSA Officer”, that's technically wrong. And it's something that an examiner or auditor could sight you for. Now, it is extremely low risk, right? Very small, right? It is low risk. I consider that to be a technical violation, but that is what the rule says. So if you're not doing that, correct it and move on, it shouldn't be a big deal.
Now, the second part of this, of course, is the contact number. So what should be listed as the contact number? Well, Frequently Asked Question No. 34 from FinCEN's FAQs addresses this. And the question in Question 34 is: Item 41 of the CTR asks for the filing institution's contact phone number. Should this be the number associated with the contact office noted in Item 40? The answer, of course, is yes.
That's all I have for you today. Thanks for watching this Compliance Clip.