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#363805 - 05/25/05 07:56 PM CTR for a Trust Account
Dip Offline
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Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
Does anyone know how to file a CTR for a trust account?

For CTR reporting, do you treat it as a joint account and use the trustees for filling in the report?
-or-
Do you treat the trust as an entity? Would the "person on whose behalf the transaction is conducted" be the trust and the trustees would not be named anywhere on the report (unless they did the transaction)?

Please help me out asap! I need to let one of our branches know!
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Dabbling in banking, law, accounting...the life of a trustee.

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#363806 - 05/25/05 08:43 PM Re: CTR for a Trust Account
Dip Offline
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Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
Wow... I've been researching this for the last half hour and I can't even find the answer on the FinCEN website. I'm 99% sure the trust needs to be named, but do I also name the trustees?

Please help!
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Dabbling in banking, law, accounting...the life of a trustee.

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#363807 - 05/25/05 08:48 PM Re: CTR for a Trust Account
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
BSA includes a trust in its definition of a "person." The trust is the person on whose behalf the transaction is conducted, not the trustees. You list any trustee(s) conducting the transaction as such, but you do not list them all unless they were all involved.
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#363808 - 05/25/05 08:49 PM Re: CTR for a Trust Account
Dip Offline
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Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
thank you so much for helping to clear that issue up!
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Dabbling in banking, law, accounting...the life of a trustee.

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#363809 - 05/25/05 08:53 PM Re: CTR for a Trust Account
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Best I could do is an old Q&A from a FIL from 1995 (FIL 70-95).

23. Question: How should trusts and other third party accounts be reported?

Answer: If Jane Doe, the trustee of the John Smith Trust, makes a reportable deposit to the Trust Account, information on Jane Doe, the trustee, including the method used to verify her identification, must be entered in Part I, Section A. Identifying information on the John Smith Trust, who is the beneficiary of the transaction, must also be reported in a separate Section A (on the back of the CTR Form). However, if the transaction is conducted for Jane Doe, the trustee, by her secretary, then in addition to identifying Jane Smith, the trustee, and the John Smith Trust, the beneficiary, in separate Section As, the secretary, who actually conducted the transaction, must be identified in Part I, Section B.
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