From:                                         Shireen Hartmann []

Sent:                                           Monday, March 14, 2011 3:21 PM

To:                                               Comments, Regulation

Subject:                                     Attention:  CTR Database


Attention CTR Database – In response to the request for comments concerning Bank Secrecy Act Unified Currency Transaction Report Proposed Data Fields.


I have reviewed the proposed fields and find some to be burdensome for the employee’s of  financial institutions’ to collect.


The following additional fields are intrusive, burdensome, and should not be added to the CTR form:


Part I -

Field 7 – Gender

Field 9 – Occupation or type of business a. NAICS code

New Data Element of County-Derived through third party data

New Date Elements for GEO Coding-Derived through third party data

New Data Element of HIFCA code-Derived through third party data

New Data Element of HIDTA code-Derived through third party date

Part I-Section B

Field 18, 18a and 19, Contact phone, Ext. & E-mail address


Part III Financial Institution Where Transaction(s) Takes Place-

New Data element of County-Derived through third party data

New Data element of GEO Coding-Derived through third party data

New Data element of HIFCA-Derived through third party data

New Data element of HIDTA-Derived through third party data


Financial Institutions’ are already overburdened with information gathering, please do not increase this burden by adding the above data fields to the Currency Transaction Report



Thank you for taking the time to review my comments.




Shireen Hartmann


Shireen Hartmann AVP, Compliance Administrator

Summit State Bank

500 Bicentennial Way | Santa Rosa, CA  95403

Direct 707.568.4946 | Fax 707.573.4631


Your local bank - Your community bank.



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