Aggregation of Secondary Acct. Holder (BSA)

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Question:

I am seeking some advise on BSA regulations around aggregation of secondary account holder. Is it a requirement by FinCEN to aggregate transactions based on secondary relationship between accounts and file a CTR? Example: Joint account relationship Account (A) - Chris (P) / Joe (S) Account (B) - Joe (P) / Brian(S) Chris as a conductor makes 6K Deposit into Act A at Branch X Later, Joe as a conductor makes 5K Deposit into Act B at Branch Y should a CTR be filed considering Joe has secondary relationship with Chris in Account A and ultimately benefits from the deposit made?

Answer:

There is no distinction between primary and secondary owners of accounts for aggregation of cash transactions for CTRs.

Chris's deposit was made on behalf of each of the co-owners of account A -- Chris and Joe
Joe's deposit was made on behalf of each of the co-owners of account B -- Joe and Brian

A CTR is required because deposits totaling $11,000 were made on behalf of Joe. The CTR will list Chris as conductor for $6,000 on behalf of himself (2a) and Joe as conductor for $5,000 on behalf of himself (2a), plus Brian as a person on whose behalf $5,000 was conducted (2c). The total deposit(s) will be $11,000. Item 3 will be checked.