John Smith does business as three different names using his own social for all three businesses.

He made a deposit into all three business accounts that totaled a reporting amount.

How do you file this CTR?

Do you have three part one for each DBA listing John’s social?

Or just one part one? If so how do we list three DBA names?

I list all three DBA names together separated by a comma and have not have any comments from auditors or examiners.

FinCEN has never blessed the listing of more than one DBA name in item 8.

You appear to have separate deposit accounts for the three DBA businesses.

If you are filing discrete CTRs rather than batch filing, you should handle the CTR as follows:

Four Part I sections.

• One for John Smith, the sole proprietor. All info on this Part I is personal, including address, SSN, gender (if on file) and any contact info.
• One for each DBA, with Owner's name, SSN, DOB, etc., but use address and contact info (phone, email) for DBA. If same as owner, use owner's address and contact info. Do not check the "if Entity" box. Put the DBA name in item 8.

The Part I for John Smith includes the total cash-in amount and all three account numbers in item 21 Each of the DBA Part I sections will have its cash-in amount and account number in item 21. All four Part I sections should have items 2a and 3 checked.

If John Smith only had one DBA, would we file with two Part 1 sections?

or just one Part 1 section?

Just one. All info is about John, except the DBA name, which goes in item 8.

And just to clarify things, if John Smith operates 6 businesses as sole proprietorships, each with a DBA name, but the CTR you are working on only involves one of those businesses, you do not involve the other 5 businesses in the CTR.

And, if your bank does not require sole proprietors to have a separate account for each of multiple DBA businesses, FinCEN does not require or suggest that you impose that requirement in order to separately break out reportable cash activity for each of the businesses.

If an LLC does business as three different names, yet uses one business account, how would you file this one?

Can you list all three DBA names in the field 8 separated by a comma? or do we have to have separate Part 1 for each DBA name listing the same account number?

As far as I can tell, FinCEN has never blessed the listing of more than one DBA name in item 8 of Part I.

In your scenario, you don't know which of the DBAs generated the cash being reported on your CTR except in the very unlikely event that there are multiple deposits and each deposit ticket indicates which DBA the deposit is from. In my world, if the business doesn't have separate accounts for multiple DBAs, the deposits are not labeled.

So you do not provide the DBA names at all in such circumstances.

Also, when an entity operates more than one DBA business, you only list the DBA or DBAs identified as making the transactions being reported. You don't identify other DBAs the entity operates.