For Customer Identification Program (CIP) purposes, how should we describe a person’s occupation if they are a stay-at-home mom? We believe FinCEN prefers the term “homemaker,” but we typically use “stay-at-home mom.” “Occupation” also appears as a field on items such as FinCEN’s Currency Transaction Report (CTR), and we want to make sure we are using the correct terminology.

We recommend setting a policy or procedure to ensure that you are using the terms “homemaker” and “stay-at-home parent” consistently for all customers who fit those labels and are not otherwise employed. Additionally, you should monitor such customers’ activities and “pay particular attention” if they “continually make large cash deposits,” as suggested in FinCEN’s guidance regarding CTR filings.

For purposes of a CTR or suspicious activity report (SAR), FinCEN’s guidance is to avoid using non-descriptive terms. In its CTR guidance, FinCEN specifically identifies “homemaker” as an example of a non-descriptive term, along with “self-employed,” “unemployed,” and “retired.” (FinCEN’s SAR guidance does not mention “homemaker” in its discussion of non-descriptive terms.) For both CTR and SAR filings, FinCEN recommends adding an individual’s current or former profession when using non-descriptive terms, with the examples of “self-employed building contractor,” “retired teacher,” or “unemployed carpenter.”

Applying this guidance to a true stay-at-home parent may not produce accurate CTR and SAR filings, however. For example, if a customer previously has worked as a teacher but quits that job to be a stay-at-home parent, we believe it would be more accurate to describe their occupation as “stay-at-home parent” rather than “unemployed teacher” or “retired teacher.” (We use the term “stay-at-home parent,” which seems to be a slightly more specific term for a stay-at-home mom than “homemaker,” which could be read as encompassing both stay-at-home parents and stay-at-home spouses who do not have children or other caretaking responsibilities. In either case, we recommend monitoring the customer’s cash deposits as suggested below.)

For purposes of CTR filings, FinCEN states that banks “should pay particular attention to customers with non-specific occupations who continually make large cash deposits.” Because FinCEN’s guidance includes “homemaker” as an example of a non-descriptive term, we recommend applying this guidance to stay-at-home parents, as you would for customers who are described as “self-employed,” “unemployed,” and “retired” without an additional term describing their current or former profession.

Also note that FinCEN’s CIP rules do not require banks to obtain information related to an individual’s occupation at account opening, although the FFIEC’s BSA/AML Manual states that banks may consider obtaining such information based on the customer’s risk profile. We recommend following the same protocols for describing an individual’s occupation at account opening as you would for CTR and SAR filings to maintain some consistency across bank functions.

For resources related to our guidance, please see:

CIP Rules, 31 CFR 1020.220(a)(2) (“Customer Identification Program: minimum requirements . . . (2)(i)(A) In general. . . . the bank must obtain, at a minimum, the following information from the customer prior to opening an account: (1) Name; (2) Date of birth, for an individual; (3) Address . . .; and (4) Identification number, which shall be: (i) For a U.S. person, a taxpayer identification number; . . .”)

FAQs Regarding the FinCEN Currency Transaction Report (“20. Is it acceptable to indicate terms such as ‘homemaker,’ ‘retired,’ or ‘unemployed’ as descriptions for occupations? When recording the occupation, profession, or type of business of the individual or entity listed in Part I, use specific descriptions such as ‘doctor,’ ‘carpenter,’ ‘attorney,’ ‘used car dealership,’ ‘plumber,’ ‘truck driver,’ ‘hardware store,’ etc. Generally, do not use non-descriptive items such as ‘businessman,’ ‘merchant,’ ‘retailer,’ ‘retired,’ or ‘self-employed.’ If words like ‘self-employed,’ ‘unemployed,’ ‘homemaker,’ or ‘retired’ must be used, however, add the current or former profession if known (e.g., ‘self-employed building contractor,’ ‘retired teacher,’ or ‘unemployed carpenter’). Financial institutions should pay particular attention to customers with non-specific occupations who continually make large cash deposits.”)

FinCEN SAR Electronic Filing Requirements User Guide, page 148 (“Item 10 Occupation or type of business: Record the occupation, profession, or type of business of the individual or entity recorded in Part I. Use specific descriptions such as doctor, carpenter, attorney, used car dealership, plumber, truck driver, hardware store, etc. Do not use non-descriptive items such as businessman, merchant, retailer, retired, or self-employed. If words like self-employed, unemployed, or retired are used, add the current or former profession if known (e.g. self-employed building contractor, retired teacher, or unemployed carpenter). If the occupation or business activity can be described in more detail, include the additional information in Part V.”)

FFIEC BSA/AML Manual, Customer Due Diligence — Overview, page 5 (“Based on the customer risk profile, the bank may consider obtaining, at account opening (and throughout the relationship), more customer information in order to understand the nature and purpose of the customer relationship, such as: . . . Occupation or type of business (of customer or other individuals with ownership or control over the account).”)