Time to update your CTR Reporting Procedures

February 12, 2020 at 9:11 am Leave a comment

Ok, so it’s not the most exciting topic in the world, but there are few BSA requirements as fundamental as filing transaction reports for currency transfers (CTRs) in excess of $10,000. On February 10th the Financial Crimes Enforcement Network (FinCEN) issued an administrative ruling updating CTR procedures when filing CTRs involving DBAs and Sole Proprietorships. The issue is trickier than it might seem at first because a sole proprietorship is a single person operating as a separate legal entity but in a personal capacity. This ruling is intended to codify precisely who the legal entity is for purposes of filing the CTR. The ruling also addresses similar concerns regarding businesses operating under a “doing business as” designation.

By the way, every time I deal with CTRs I’m reminded of just how antiquated this requirement is. Since everyone knows a financial institution has to report these cash transactions, then how useful is this requirement in terms of catching the bad guys? Everyone agrees that it’s time to update the reporting threshold, but unfortunately the threshold is embedded in statute. Perhaps this is smoothening we can talk about when we go to meet with our Congressional Representatives in a week and a half.

Again, I know this is not the most exciting issue in the world but on a practical level, it would be a big help for financial institutions big and small.

Entry filed under: Compliance, Regulatory. Tags: , , , , , , .

Let’s Deal With the Medallion Mess, Once and For All A Tale Of Two Budgets: Why It Matters To Your Credit Union

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

Trackback this post  |  Subscribe to the comments via RSS Feed


Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

Enter your email address to subscribe to this blog and receive notifications of new posts by email.

Join 653 other followers

Archives