Answer:
You are correct. The two businesses' cash deposits should be aggregated and a single CTR filed, with Jim Shoe, Inc., in Section A. If you review examples 5 and 6 in FinCEN's most recent Ruling on CTRs for DBA Customers, you'll see there are two ways you can complete the CTR.
The first option (as demonstrated in Example 5) includes information on the corporation in Section A, with the DBA names in item 5. There's no need to provide separate addresses for the individual businesses, or separate TINs (if they have them).
The second option (see Example 6) includes a separate Section A for the business. In your case, you'd create three Section A entries: one each for the corporation, the corporation DBA Jim #1, and the corporation DBA Jim #2. In this method, you'd provide the address corresponding to the party being described, along with that party's TIN (if it uses a separate EIN).
First published on BankersOnline.com 5/26/08
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