We have a parent corp that owns 8 DBAs. One of the companies has made a deposit that requires a CTR. Because they are all owned by the same parent company, should we complete Part 1 for all 8 sub companies? Thanks!

Not sure why you have to list the other 7 DBA's - they were not involved. The ultimate filing is on the holding company.

Thank you!

Sorry, I just reread my post. I didn't make this part clear. The account is set up Holding Company D/B/A company #1, D/B/A company #2, D/B/A company #3, etc, etc. They all deposit into the same checking account number. I'm not really sure why this was set up this way, this was before my time. We can determine which of the companies made the deposit, as they have purchased deposit tickets for each of the 8 DBAs and the name that belongs to that entity has their name, the next one their name, etc. But all 8 dba's deposit into the same account.

Include a Part I for the legal owner of the businesses. Provide the location and any contact (phone/ email, etc.) for the headquarters of the company.

Because only one of the DBAs is involved in the deposit, add that DBA name to item 8. Do not list the other DBAs.

That's all.

If more than one of the DBAs were in the deposit, and you knew it, you would create separate Part I sections for each DBA plus a Part I for the company that operates them.

Thank you!

If more than one of the DBAs were in the deposit, and you knew it, you would create separate Part I sections for each DBA plus a Part I for the company that operates them.

Does this apply only if the DBAs each have separate location?

What if the DBA location is the same as the headquarter location?

From the CTR XML, Attachment C, Instruction 17, with bullet list rather than text, for clarity:

17. Sole Proprietorship. A sole proprietorship is a business in which one person, operating in his or her own
personal capacity, owns all of the business’s assets and is responsible for all of the business’s
liabilities. Consistent with the definition of “person” in the Bank Secrecy Act’s implementing regulations, a sole
proprietorship is not a separate legal person from its individual owner.
• Thus, when a CTR FinCEN Form 112 is prepared on transactions involving a sole proprietorship, a financial institution should complete a single Part I “Person Involved in Transaction” section with the individual owner’s name in Items 4 through 6, gender in Item 7,
and date of birth in Item 17.
• If the individual owner is doing business in his or her own name, then the rest of Part I should be completed reflecting the individual owner’s information. If the individual owner is operating the business under a different name (a “doing business as” or “DBA” name), then such name should appear in Item 8 “Alternate name,” and the rest of Part I (other than Items 4-6, 7, and 17 identifying the individual owner) be completed with reference to the DBA name.
• If the individual owner operates under multiple DBAs, then a separate Part I section should be completed for each different DBA involved in the transactions. The amount and account number(s) entered in Item 21 “Cash in amount…” or Item 22 “Cash out amount…” will be the amount and account number(s) associated with the specific location corresponding to the reported transaction

The last instruction is poorly written. It refers to multiple DBAs and the need to use a separate Part I for each involved DBA. But it closes with referring to "specific location." Perhaps whoever wrote this instruction just assumed that each separate DBA would be conducted at a separate location. I don't think that reflects reality in all cases. A sole proprietor's multiple businesses (each with its own DBA name) might all operated under the same roof, sharing the street address, phone number, but with separate websites, email addresses. Or the businesses might be separately located. And there might be sole proprietors who operate at multiple location but with different combinations of his/her DBA businesses at each location.

I'd break things down according to what sorts of separations you see in the bank's records. If the proprietor has a separate account for each DBA business, and two or more of those DBAs are involved in a CTR, create a separate Part I for each DBA, with a single Part I for the owner. I think this is the way most multiple DBAs of a single owner are broken in most banks, since many banks limit an account to one business.

If you don't have things broken out that way (for example, you have customers with multiple DBAs operating in a single account), don't break them down. Do a single Part I and don't provide DBA names at all.

This could change if FinCEN has time to revisit instructions 17 and 18 (which deals legal entities with multiple locations and possible DBAs) to clean them up.[quote][/quote]