CTR Reporting-Aggregation of Multiple Transactions

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Question:

For the purposes of CTR reporting, does aggregation of multiple transactions include multiple entities? A couple of examples: we have an individual who owns three MSB entities, separate tax IDs, different names, and operates in three different towns. Should their cash transactions be aggregated? If so, who goes on Part A of the CTR: the owner and/or all three entities? Another scenario: a customer has a joint account, a corporate account, and is a signer on their child’s account. If cash is deposited into all three accounts by one of the joint account holders, an employee of the corporation, and the child into each respective account. Which accounts would be included on a CTR and reported under who's name? The other scenario: if it makes a difference, is you do not know who made each of those three deposits, should they be aggregated? Bottom line: how far does aggregation go?

Answer:

Aggregation is by entity and by transactor. So the deposits to three separate entities don't get aggregated unless they are made by a common transactor. The same reasoning gets applied to the second scenario. If multiple deposits are made by one transactor, aggregate them regardless of who owns the accounts. If multiple deposits are made to the same account, aggregate them regardless of who made the deposits.

First published on BankersOnline.com 7/24/06