Our BSA officer has informed us that if an entity has several secondaries on the account, such as authorized signers, owners and so on, that we have to include them all on the CTR when filling one out. Is this correct?

You do not say what type of 'entity' it is but the simple answer is NO.

I do not put authorized signers on the CTR. Only the account owners, be they a commercial entity or a living person, as beneficiary and whomever conducted the transaction as the transactor.

Include:

1) the entity on whose behalf the transaction is conducted
2) person(s) making the deposit(s)

There are, of course, other scenarios (i.e. deposits made via night drop).

Most commonly at my bank, we have the entity listed (ABC, Inc) and the person making the deposit (Suzy Que).

Your BSA officer (1) made a mistake; (2) failed to communicate effectively; (3) was misunderstood; or (4) needs to do some remedial CTR 101 study.

A mere signatory on an account is never reported on a CTR unless he or she is also the person conducting the transaction on behalf of the account owner.

Of course there's the DBA business account where the "entity" (Joe's lawnmower service) is treated just as if it's a personal account. Then you would include all the owner and Joint owner humans for deposits made.

Cornhusker, the laws may vary by state - in Texas, a sole proprietorship is owned by one person; at our bank, we don't treat the business account as though it's a personal account.

The business account shows the SP as the owner and anyone else is an authorized signer. As such, our CTR would reflect the SP. If someone other than the SP made a deposit into the account, they would be listed as making a deposit on behalf of the SP.

And across the Red River in Sooner Country, an SP can be owned jointly by husband and wife. In such cases, a CTR for a reportable deposit would look very much like a CTR on a deposit to any other joint account, aside from the entry in item 8.

Thank you everyone for your insight on this topic. It has helped me tremendously.