Sole Proprietor CTR-Use TIN or SSN#?

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Question:

When filing a CTR on a sole proprietorship where the owner has a separate TIN for the business, which do we supply on the CTR- the SSN for the sole proprietor or the TIN?

Answer:

It depends on which of the two acceptable filing methods you use under FinCEN's ruling FIN-2008-R001. If you use the option to report only one person on whose behalf the transaction was completed (the individual), you use his or her SSN and other personal information. If you use the option that treats the business as a separate person, you create one entry for the individual with his or her information and a second one for the business, using the business address and EIN.

First published on BankersOnline.com 11/05/12