Having a conversation with our compliance officer in the proper manner to complete the following CTR scenario:

John Doe and Mary Smith dba ABC Market(Partnership account with it's own separate EIN).

$15,000 deposit into account conducted by Mary.

How are Part I Section A and Section B completed?

It is my understanding that the Part I Section A should list "ABC Market" (line 2 with corresponding EIN on line 6)only since it's a Partnership with its own EIN. Part I Section B lists Mary Smith as the conductor.

OR

Do need to have multiple Section I Part A's for the Market and then John Doe dba ABC Market and the third Part A listing Mary Smith dba ABC Market, with their own SSN.

OR

Is it Mary Smith dba ABC Market, conducted on its own behalf (Section I Part B), in the first Part I Section A
followed by John Doe dba ABC Market and ABC Market.




Please advise. Thanks.

Who is the EIN assigned to? ABC Market? or Joe Done and Mary Smith, Partnership? The name in Part 1 needs to match the EIN filed or you will get one of those nasty letters returned to you.

bump

ABC market is the benfactor and mary Smith is the transactor, unless there is something I'm missing.

That is what I thought; however, my compliance officer is telling me that because it is a deposit into a partnership dba, we need to show ALL individuals that benefit from the transaction.

I thought because the market had it's own EIN, then it would be sufficient to just reflect the Market and NOT the individual partners.

Thanks....

No. The partnership is its own entity for this purpose. This isn't a joint account. It's an account of the partnership. In other words, the partnership is owned by more than one person, but the account is only owned by one "person" -- the partnership.

John...thanks for the response. However, can you please elaborate on the "No"? Is the No to the compliance officer's position or to my position?

Thanks again for your input.

No to the CO. Sorry for the confusion.

Your CO might want to read the definition of "person" in the CTR instructions. A person includes legal entities and organizations. It is not necessary to also show the owners in Part I, Section A. Thank goodness --- or we would all be crazy!!!!