Compliance Question of the Week

Are we supposed to give a member a copy of the Currency Transaction Report (CTR) we are filing just because he wants one?

There is no rule by FinCEN that mandates a credit union give a copy of the CTR to the affected member. The credit union does have several options:

  • Give the member a copy of the CTR;
  • Give the member a blank CTR;
  • Show the member the completed CTR, but do not provide a copy;
  • Develop a policy of not giving out copies of CTRs;
  • Develop a policy of giving out copies of CTRs; or
  • Direct the member to the FinCEN website for additional information

It is important to remember that a Suspicious Activity Report (SAR) cannot be disclosed to the member and a copy should never be provided to the member.

Related Links:

FinCEN CTR Pamphlet
FinCEN Guidance

 

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted in Compliance.