I have an out of town Cashier's Check payable to "Jane Doe" who endorsed and gave the check to "Daisy Duck". I want to report the CTR with "Jane Doe" as the benefactor and "Daisy Duck" as the transactor. Is this correct??

Our tellers always select the person standing in front of them as the benefactor no matter what and then I have to correct the CTR and have the teller attempt to obtain the necessary info after the fact for the correct benefactor.

Thanks.

Benefactor - one who bestows a benefit upon another.
Beneficiary - one who benefits from an event or transaction
Instruction for Section A of CTR (paraphrased): Enter information on the person(s) on whose behalf the transaction to be reported was conducted.

Without asking Daisy on whose behalf she is cashing the checks, you should assume she's doing it for herself. Your teller could inquire of Daisy, "Are you cashing the check for yourself, or on behalf of Jane Doe?" Alternatively, Daisy might offer, "I'm cashing this check for Jane because I have an account here, and she doesn't."

Unless your teller gets information concerning the transaction, your assumption that the check is being cashed on behalf of the payee has less validity, IMO, than the teller's assumption that the individual in front of her/him is cashing it for himself or herself.

Jack Henry's Vertex teller system uses the word "benefactor" for Part I Section A of the CTR. I know this causes confusion.

Examiners/auditors have questioned and have had us amend CTR's in cases such as this, so I question myself on how to properly file.

Thanks.

If your examiners or auditors can say categorically that the payee on the check always goes in Section A they must have some unpublished guidance from FinCEN. Ask them for it. If they don't (my guess) they are offering you a personal opinion that is worth less than what you paid for it and would not prompt the filing of a correction from me.

If your teller asks the question, there is some basis for filing the CTR based on the last endorser's answer. If not, it's a coin toss and I would opt for the last endorser in Section A. (... if for no other reason than the fact that she is the person whom I can fully identify.)

As always, the tie breaker is a call to the FinCEN Hotline.