How to Fill Out New CTR for Business Deposit

Answered by:

Question:

I am trying to fill out the new CTR form and do not know how to do the boxes and blanks when a person comes into the bank and makes a deposit for a business. On the old form, we put the business name and EIN in the PART 1 section A and then put the person who conducted the transaction in Section B of Part 1. The new form #20 - is this info on the person that actually makes the deposit? I would think I check box 2c but then I do not know where to put the employee's info. I see the + - buttons at the top but do not know if this is when you use them. Any help would be great.

Answer:

If you were completing a CTR using the legacy format, you'd list information on two persons -- the business on behalf of which the deposit was made and the individual who made the deposit (the conductor). Using the FinCEN CTR format involves the same two persons.

Start by completing a "Person Information" entry for the business (this approximates your completion of a Section A entry on the Legacy CTR). Click box 2c and proceed to provide information on the business. In item 20, use information on items you used to verify the business' existence and identity in the CIP process. Typically, you'll check the "other" box and key in a brief description of the document type to the right of the "other" box, add the document number (if you recorded a document number during CIP or later) and the country and state (assuming, for example, the document was a corporate filing with the state). Item 21 is for the amount of cash deposited and the account number(s) into which it was deposited (you can add additional account numbers by clicking the "+" button to the right).

Go back to the top of the "person" page and click the "+" button to create a second person page. You complete this page on the individual making the deposit (approximating your completion of the Section B entry on the Legacy CTR). Check box 2b. Item 21 on this entry reflects the amount of cash this individual deposited to the account, and the account number(s) involved.

First published on BankersOnline.com 4/22/13