Hello all - I'm struggling with how to complete this CTR. We have a corporation that has multiple fictitious names all on one account, so it's titled:

ABC Inc. DBA Tool Supply
ABC Inc. DBA Sunset Tools
ABC Inc. DBA Sunrise Tools

They made 5 deposits which in total exceeded $10,000. They were all conducted by the same person. I've read the FinCEN guidance on the fictitious names, but it doesn't seem to cover this situtation. We're also using the new CTR. So do I complete 4 separate part 1's? 3 with the Corporation and the different fictitious names in the "Alternate Name" field and one for the conductor?

Also, I'm struggling with number 21 "Cash in amount for individual or entity listed in Item 4" on the new CTR for these types of transactions, where you have a business and a conductor. Do you list the "cash in" under the business section or the conductor's section?

I would appreciate anyone's input on this.

You list the cash in for both the person on whose behalf... and for the conductor. If there's only one transaction being reported, the amount will be the same and will also appear in item 25, 26 or 27, as applicable. But (for illustration) if you have three conductors making three deposits to one business's account, you list (again, an example) $5,000 on conductor 1's page, $5,000 on conductor 2's page and $6,000 on conductor 3's page, but the total of $16,000 on the business's page.

As for the multiple DBA names, the only technically correct way to file it would be to complete only one "on whose behalf" page for the CTR (the old Section A), and I'd list at least one of the DBA names. As far as I know, FinCEN has not offered a suggestion on what to do when there's more than one DBA name.

I would list all 3 DBAs in the ficticious name line and separate them by commas. I've done it once on the new CTR and had no issues.

I'd agree with Dani, assuming sufficient character space. Has anyone had a conversation with the Help Desk on this question?

Thanks John & Dani!

I called the Help Desk several years ago to inquire as to whether all DBA names for a legally organized business had to be listed on the CTR. I was informed that it would not be necessary if all of the businesses were similar in nature - such as three shoe stores. If two were shoe stores and one was a gas station they would prefer I listed at least one of the shoe stores and the gas station. In reality, all were gas/convenience stores, so I chose to list the first one appearing in our account list since it automatically pre-filled my form.

Since it has been a few years, it might be worth another call to clarify.

Given the design continuity of the two forms, I find it odd that the SAR allows for multiple DBAs/AKAs per person, but the CTR (which I would assume has the far greater incidence) does not.

I left a message with the question on Thursday but (also oddly) did not get a response. I renewed the request this morning.

I called the Helpline...

If there is a single person (entity or individual) on whose behalf the transaction is conducted with multiple transactions involving multiple accounts with different DBA names, the bank is to list the DBA name in connection with the largest cash amount involved. The other DBA names should be readily identifiable on request, but need not be listed on the CTR.

Had I guessed, this is not what I would have guessed...