Answer by Ken Golliher: From the Q & A in FinCEN's October 4, 2012 webinar on the CTR and DOEP:
Q: How do I complete a FinCEN CTR when the funds are being deposited or withdrawn from a joint account?
Scenario: Person 1 deposits $15,000 in an account jointly owned by Customer A and Customer B.
The financial institution would file a CTR and complete a Part I for Person 1 (the transactor) by selecting Item 2b "Person conducting transaction for another" and a Part I for each, Customer A and Customer B, by selecting Item 2c "Person on whose behalf transaction was conducted."
Answer by Brian Crow: FinCEN's Q & A seems to indicate that a person other than an owner made the deposit as it differentiates Person 1 from Customer A & B. If Customer A makes the deposit, then select Item 2a "Person conducting transaction on own behalf" for Customer A, and select Item 2c "Person on whose behalf transaction was conducted" for Customer B.
Answer by Ken Golliher: Agreed.
First published on BankersOnline.com 1/14/13