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#1213497 - 07/07/09 04:16 PM CTR Multiple Persons
1banker Offline
New Poster
Joined: Jan 2009
Posts: 16
Husband and wife withdrew $15,000 in cash and told the bank it was for the benefit of the wife. To attempt to avoid a CTR, each spouse withdrew an amount less than $10k from their joint account. How do we fill out the CTR? Our plan was to put the wife in Section A, Check "Conducted on Own Behalf" for the first Section B, and then put the husband in the second Section B. However, BSA E-Filing seems to require a completed Section A when multiple persons is checked. Any ideas?

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#1213515 - 07/07/09 04:40 PM Re: CTR Multiple Persons 1banker
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
I am not an e-filer but your plan seems correct to me. Aside from a CTR I would also suggest a SAR for the intent.

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#1213520 - 07/07/09 04:45 PM Re: CTR Multiple Persons devsfan
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
I've noticed that with BSA E-Filing & the only option I've been able to come up with is to fill out 2 Section A's on the wife ...
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#1214883 - 07/09/09 03:20 PM Re: CTR Multiple Persons WonderWoman
1banker Offline
New Poster
Joined: Jan 2009
Posts: 16
Thanks for the advice. I spoke with someone at the FinCEN help desk who said to go ahead and put the husband in the second section A, only because E-filing does require it to be filled out and it's "not wrong" to do it that way. It's just one person's opinion, but he did do some research on it and call me back, so I hope he's right.

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#1216731 - 07/13/09 08:54 PM Re: CTR Multiple Persons 1banker
Data Offline
100 Club
Data
Joined: Oct 2002
Posts: 226
Houston
For BSA Efile discreet filers you have make 2 section A's if you have 2 conductors. The same person may be in both section A's. Just a little glitch it the system.
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