Filing a CTR for a Custodial Account

Question:

We had a customer come in and make a deposit over 10K to a custodial account on which she is not a signer. Whose information do we place in Section A of the CTR: the custodian's or the minor's?

Answer:

I suggest you fill out one Section A for the minor and another for the custodian.

Please understand, I personally believe that only the minor benefits from the transaction. Regardless, in the past FinCEN has issued interpretations regarding trusts, estates, and attorney escrow accounts that indicate the fiduciary should also be listed in Section A. While I do not agree with those interpretations, your concern should be on what your examiners agree with.

First published on BankersOnline.com 1/10/11