Q: Is a “form of identification” (Item 20) required for an entity? If so, what information would we enter in that field?
A: For technical filing purposes, Item 20 is a critical field on the FinCEN CTR (identified by the *). However, the release of the FinCEN CTR did not create any new obligations or otherwise change existing statutory and regulatory expectations of financial institutions in filing the new report.
The previous guidance for completing the identification field on the CTR for an entity instructed filers to check the “Other” box and enter “NA” on the line provided. That instruction is no longer valid given the addition of the “Unknown” box for Item 20. The addition of the “Unknown” box means that filers will no longer use “NA” or “XX” in certain fields.
Therefore, if the filing institution does not have information available or knowledge of a “form of identification” for the entity, it should check the “Unknown” box for Item 20.
FinCEN expects, however, that financial institutions will provide the most complete filing information available within each report, regardless of whether or not the individual fields are deemed critical for technical filing purposes. Examples of “forms of identification” for an entity could include the entity’s business license or incorporation documents. Please refer to 31 CFR § 1010.312 for additional information on identification requirements.
Please note that if “Other” is selected in Item 20, you must either put in the number associated with that other form of identification or space fill the “Number” box to avoid a validation error.
This FAQ was obtained from FinCEN’s website, FinCEN CTR FAQs section, which may be found here: