Question:

Heather,

We had a non-member cash a check that was written to him from a credit union account in the amount of $25,000. Are we required to file a Currency Transaction Report (CTR) for this non-member? We have his license, but we do not have his Social Security Number (SSN) and the CTR system will require it, so I want to know if I need to call him to get his SSN?

Great Question!

Yes, you are. So that’s a significant bummer.  You should be able to indicate on the CTR that the Tax Identification Number (TIN) is “unknown.”  But I would definitely try to get it from the non-member if you can. The TIN is a “critical” field on the CTR and you’ll get dinged by examiners if you submit the CTR without it.  You also should try and get this person’s occupation (a non-critical field, but get it if you can). Thankfully you did get his name, date of birth and address (hopefully physical address – if it’s a PO Box, you’ll need to ask for that too) on the driver’s license.

I hope you are successful in obtaining missing information now, but its highly possible you might not be.   This can be an excellent training opportunity though. At the next staff meeting, make sure you go over this situation thoroughly with your staff.  They will occasionally need to gather CTR info on non-members.  They may be like this guy – cashing an on-us check, or they might be someone coming in to deposit cash into an employer’s or another person’s account.

You are required to gather CTR information for everyone who conducted the transaction or benefited from the transaction. The best time to get CTR information from non-members is when they are standing in front of you.  If they don’t have ID or won’t provide info, you don’t process the transaction.