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#1051317 - 09/26/08 03:11 PM CTR - conducted on own behalf?
Sunshine_101 Offline
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Sunshine_101
Joined: May 2005
Posts: 127
Okay, so this may seem like a dumb question but I'll ask anyway. Here is the scenario:

Jon Doh deposits $12,000.00 into his business account, ABC Company, an hour or so later Jon Doh deposits $5,000.00 into a personal account.

?????Would the CTR be completed as.....?????

ABC Company as the benefactor along with Jon Doh; conducted on own behalf (Jon Doh was the one who conducted both transactions) or would it be ABC Company as the benefactor along with Jon Doh; with Jon Doh as the transactor and not select conducted on own behalf???????
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#1051326 - 09/26/08 03:14 PM Re: CTR - conducted on own behalf? Sunshine_101
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
Easiest way to complete the CTR is to show John on page 1, Part 1 Section A, check box e in Section B (so you don't have to repeat all of John's info), and show ABC Co on page 2, Part 1 Section A. You would also check boxes 1b and 1c on the top.

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#1051343 - 09/26/08 03:21 PM Re: CTR - conducted on own behalf? devsfan
Sunshine_101 Offline
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Sunshine_101
Joined: May 2005
Posts: 127
Okay, could you please explain why the CTR should be completed this way? I'm having a little trouble with it, because to me, it seems that we are saying that the business also conducted it's own business by selecting conducted on own behalf. Just by putting Jon first on the CTR and conducted on own behalf makes it so that the CTR isn't really indicating that the business on the second page was conducted on own behalf as well? I need some help making sense of this so that if this happens again I will be completely sure of my decision.
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#1051381 - 09/26/08 03:40 PM Re: CTR - conducted on own behalf? Sunshine_101
Sunshine_101 Offline
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Sunshine_101
Joined: May 2005
Posts: 127
If anyone can explain why the CTR should be filed this way I would greatly appreciate it. A big thank you in advance.
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#1051444 - 09/26/08 03:56 PM Re: CTR - conducted on own behalf? Sunshine_101
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
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Central City, NE
I agree. Why? As devsfan stated - easiest way so you don't have to repeat all of John's info.
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#1051989 - 09/26/08 08:23 PM Re: CTR - conducted on own behalf? David Dickinson
Maytagman Offline
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Maytagman
Joined: Jun 2008
Posts: 285
South
Bug, I think your question is: "Where page 2, section B states 'Individuals Conducting Transaction(s) (if other than above),'" to which section does it refer? In years past, I had thought it referred to the section A IMMEDIATELY above page 2's section B, as you apparently do. I discussed with my regulator the concepts mentioned above, and the regulator agreed that "if other than above" can refer ALL the way back to page 1 (the conductor identified on page 1, either by name in Section B on page 1 or by the "conducted on behalf" or whatever box is checked in Section B to explain B's blankness).

Last edited by Maytagman; 09/26/08 08:29 PM.
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