One of the common errors we continue to see on Currency Transaction Reports (CTRs) is with the RSSD (Research, Statistics, Supervision, and Discount Number) fields. Part III, Item #39 asks for the Financial Institution ID Type and ID Number. This is where you select RSSD for the institution type and provide the RSSD number for the location where the transaction took place. Bank’s often enter the main bank’s RSSD# when the transaction took place at a branch location. This is incorrect if the branch has its own RSSD#. When the transaction takes place at a branch, you should include the RSSD# associated with that branch. However, if the branch location at which the transaction occurred does not have an RSSD#, you should leave all of Item 39 blank. If the branch has the same RSSD# as the financial institution as a whole, use the overall financial institution RSSD#. This is common with credit unions.
Not sure if your branch(es) have a separate RSSD#? Here’s where you can find out: https://www.ffiec.gov/nicpubweb/nicweb/SearchForm.aspx. After entering your bank’s name, city and state, click Submit. This screen is only the first step, as it only shows the main bank’s RSSD# under Name (RSSD ID). To find out if your branch(es) have a separate RSSD#, you need to click on your bank’s name and from the next screen, you need to click on Branch Locator near the top right. This will bring up another screen where you can either enter a state, or if you have branches in several states, leave the state blank and click Submit. The final screen will result in the RSSD# for your branch(es).
Do you have other questions or frustrations in completing the CTR? You are in luck! Join us for our CTRs, Exemptions and Monetary Instruments Compliance Webinar on August 15, 2017, where we will walk you through completing the CTR line by line. We’ll also cover the recent changes FinCEN made to the CTR form.
Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!