If I am completing a CTR on an LLC using the sole member's SSN would part 1, section A, Line 2 have the member's name and line 5 have the LLC name? Would I complete lines 8, 13 and 14 with the member's information or with the LLC information?

This is one of those questions you're almost afraid to ask because the answer might be really bizarre, since the CTR format simply doesn't accommodate reporting easily on a single-member LLC.

If you're interested in getting a match between the SSN and the reported name, you'd want to put the individual's name in items 2,3, and 4. But that simply goes contrary to the basic rules on filing CTRs. You report the person that benefited from the transaction in Section A, and that person is the LLC, not the individual who happens to be the LLC's sole member.

This isn't a sole proprietorship where we know that the business and the owner are the same person so we can come up with a way to make the form work. This is truly a case in which a separate entity can "borrow" an individual's SSN for tax purposes.

So, unless I hear a different interpretation from FinCEN, I'd suggest that you complete the CTR as if the SSN belongs to the LLC, and simply respond to the inevitable error message from the IRS that it's the correct number for the LLC under IRS rulings.

The rest of Section A should also be about the LLC, not its member.

Thank-you.