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#2069553 - 03/16/16 03:30 PM CTR ?, Business Acct, and Personal
Matt_B Offline
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Matt_B
Joined: Sep 2011
Posts: 1,648
A CU, Where Regs Don't Apply
Old story, but still hanging up on this one because it was all in one transaction.

John comes in with $17500. He hands teller the whole pile and says "Payoff my truck loan on my construction LLC account, and put the rest in my personal savings account."

Teller puts ~$12,500 on the loan to pay off the vehicle (John sold it), and puts the rest (~$5,000) in the personal account, all in one transaction, one receipt. (Don't get me started on how they decided to be lazy and create a complicated situation that didn't need to be complicated.

Single-member LLC, he and wife Suzy are authorized signers, he and wife are both on personal account as well.

Option 1: LLC is one beneficiary of the transaction, gets a page filled out for the $12,500. John and Suzy each get a page for the full dollar amount, or just the $5,000 to their personal account
Option 2: Just John is on for the person conducting the transaction and LLC for on behalf of, and Suzy's not involved at all since she only received $5,000?
Option 3: Something else I'm missing?
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#2069558 - 03/16/16 03:46 PM Re: CTR ?, Business Acct, and Personal Matt_B
MollyM Offline
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Joined: Jul 2005
Posts: 127
Mississippi
LLC is beneficiary for the $12,500 loan payment.

John and Suzy are beneficiaries for the $5,000 deposit only.
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#2069559 - 03/16/16 03:47 PM Re: CTR ?, Business Acct, and Personal Matt_B
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,784
Illinois
Since John brought in the full amount, the transactions are aggregated for CTR purposes. Your procedures should dictate whether or not you will check the "multiple transactions box" for John.

FinCEN CTR FAQ #18 "...There may be instances where, at one time, an individual brings in funds to deposit to multiple accounts at the financial institution. Whether or not to check “Multiple transactions” in these instances depends on the financial institution’s procedures. For example, a customer brings in $15,000 and deposits the funds to three different accounts; the financial institution posts each transaction individually, choosing as a matter of policy to define each as a separate transaction. When completing Part I on the conductor, the financial institution would check Item 3 “Multiple transactions” as a result of its procedures to post the transactions individually and treat each one as a separate transaction."

Part I LLC - Box 2c $12,500
Part I John - Box 2a $17,500 - John brought in all the money so he was involved in the full amount
Part I Suzy Box 2c $5,000
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#2069565 - 03/16/16 03:56 PM Re: CTR ?, Business Acct, and Personal Matt_B
Matt_B Offline
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Matt_B
Joined: Sep 2011
Posts: 1,648
A CU, Where Regs Don't Apply
Thanks for the perspective and responses, both of you!
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#2299032 - 07/05/24 07:48 PM Re: CTR ?, Business Acct, and Personal Matt_B
SmallBank3 Offline
Member
Joined: Nov 2019
Posts: 61
Resurrecting this for a tiny bit more clarity.

Scenario is John making a deposit for the Church account (he's obviously not the "owner") and also making two deposits into his personal accounts. Integrated Teller prompts for a CTR. Part I Box 2 only allows one selection but both 2a and 2b apply to John in this instance. Do I just select 2a and consistently choose the same in all future situations (which isn't entirely accurate) or do I do two Part I's for John with one 2a selected and one 2b selected (which feels redundant but is at least conveying the information accurately) with the appropriate amount for each captured?

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#2299034 - 07/05/24 09:05 PM Re: CTR ?, Business Acct, and Personal Matt_B
John_Burnett Offline
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John_Burnett
Joined: Feb 2013
Posts: 417
Cape Cod
You complete two Part I sections for John because he is conducting transactions in two different capacities (on his own behalf and on behalf of another. You are correct -- it is somewhat redundant, but it tells law enforcement how to understand what John did.
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#2299035 - 07/05/24 09:18 PM Re: CTR ?, Business Acct, and Personal Matt_B
SmallBank3 Offline
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Joined: Nov 2019
Posts: 61
GREATLY appreciated John! It's what I thought was correct but then felt less confident after reading above.

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#2299182 - 07/10/24 08:12 PM Re: CTR ?, Business Acct, and Personal Matt_B
John_Burnett Offline
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John_Burnett
Joined: Feb 2013
Posts: 417
Cape Cod
Yes. Note also that Brian's analysis from 2016 was fine then, but the CTR would look different if the transaction occurred today, in 2024.

John would get two Part I entries. One for the $5,000 deposit to the joint account with Suzy, with item 2a checked, and one for the $12,500 deposit to the LLC, with box 2b checked. And box 3 will be checked because John is included in the CTR twice.
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