How to Complete CTR for Business DDA Account

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Question:

We have a customer that has a Business DDA with the first name line his own, tied to his own social and the second name line his dba tied to an EIN. If he deposits over $10K cash into THIS business account how is our CTR to be completed? Our "tax" line is tied to the DBA and its EIN. Please advise.

Answer:

It really doesn't matter how the "tax" line is set up. It appears that the business is a sole proprietorship. There are two different approved methods for filing the CTR described in FinCEN's Administrative Ruling.

You can either file the CTR just on the individual using his SSN, address and date of birth, adding the DBA name in item 5, or you can file a CTR with two Section A entries. If you choose the latter option, create one Section A entry for the individual with his personal information and the second Section A entry listing the individual, the DBA name, the business address and EIN and nothing in the date of birth field or in item 14.

Read the examples in FIN-2008-R001 for more detailed information.

First published on BankersOnline.com 3/19/12