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CTR on a Rep Payee Account Q & A - Follow Up

Answered by: 
John Burnett

Question: 
According to the Guru Q&A <a href="http://www.bankersonline.com/security/guru2007/gurus_sec121007b.html">"CTR on a Representative Payee Account"</a>, when a representative payee conducts a transaction that requires a CTR the Rep Payee and the Beneficiary should both be put into section A with the Rep Payee also in B as conductor. My supervisor doesn't agree and I need to explain why your answer is correct, but I can't find anything online. Why should the CTR be done the way it is described in the Q&A?
Answer: 

The transaction is completed on behalf of the Rep Payee because he/she controls the funds in the account. It is completed on behalf of the beneficial owner of the funds because, well, he/she is the beneficial owner. And of course, the Rep Payee is the individual named in Section B (by checking off "conducted on own behalf"). Take a look at this old (1995) Q&A on CTRs and scroll down to Question 23 for a parallel situation.

First published on BankersOnline.com 12/15/08

First published on 12/15/2008

Filed under: 
Security
Filed under security as: 
Beneficiary
IT
Representative Payee

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