Does a CTR need to be completed for the following?

The State Trust Account Foundation has numerous IOLTA's that use one EIN. On one day, an aggregate of $10,000 was deposited into muptiple accounts. Each account has different owners but each owne has the State Trust Account Foundation EIN. Would a CTR be filed for the State Trust Account Foundation?

You need to complete a SAR if a person (natural or otherwise) conducts or benefits from cash in or out exceeding $10,000. If these accounts are structured as I believe they probably are, no one account owner reached a reportable limit. On our system we establish each IOLTA in the name and true TIN of the attorney or firm. We use an alternate TIN on each account for IRS reporting purposes (i.e., the TIN of the IOLTA beneficiary), but we are able to aggregate cash transactions appropriately for each attorney and law firm. (The beneficiary of the interest is not the account owner.)

If you have defaulted the IOLTA beneficiary's EIN on each IOLTA account, how can you accurately aggregate your transactions for CTR purposes? You might want to see if you have another option for IRS reporting that will not negatively impact your CTR aggregation.

I hope this makes sense.

I think Brenda means "CTR" in her first sentence. But I agree with everything else she says.

Of course, I do. SORRY. Guess you can tell on what I'm working on this week, huh?