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#1108613 - 01/09/09 08:49 PM CTR completion
nemsi Offline
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Joined: Nov 2005
Posts: 383
I have just completed an "online CTR training". We're thinking about using this training. I had a couple of issues that I don't agree with and wanted to see what you guys think about this scenario:
Pastor Sam is the pastor of 3 churches. All the churches do business under the same tax ID and all deposits are made into the same account. Deposits from the 3 churches exceed 10,000. How many section A's do you have?

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#1108764 - 01/09/09 10:02 PM Re: CTR completion nemsi
Steve Doty Offline
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Joined: Mar 2007
Posts: 137
Nebraska
If all churches are under the same tax id. that would be considered one entity. I would say "1" section A.

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#1108777 - 01/09/09 10:12 PM Re: CTR completion Steve Doty
rdelgado Offline
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Joined: Dec 2005
Posts: 116
I only see one Section A in that scenario. Whoever owns the account is the only 'known' beneficiary as far as I can tell. Seems to me the money could come from fifty different sources, the only one benefiting is the account holder.

My opinion for what it's worth.
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#1108800 - 01/09/09 10:29 PM Re: CTR completion rdelgado
nemsi Offline
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Joined: Nov 2005
Posts: 383
That was my answer and that answer was said to be incorrect. The correct answer as it was written "Complete a separate Section 1 for each physical church location, even it multiple CTRs must be used." Strange.

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#1108910 - 01/11/09 03:05 AM Re: CTR completion nemsi
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,786
Cape Cod
The information you need is whether the three churches are in fact separate legal entities or a single entity with three locations (and three different names). It looks, at first glance, that there is one entity, so you use one Section A. However, churches don't always operate according to the rules you'd expect them to adhere to, especially if they are small, unincorporated operations. Given the information you got in the question scenario, I think the test answer is wrong.
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#1108991 - 01/12/09 02:14 PM Re: CTR completion John Burnett
nemsi Offline
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Joined: Nov 2005
Posts: 383
Thanks everybody. I am just so frustrated because this training is available at $0 expense to the bank which is the amount that I have for training. I do think the answer is incorrect.
Another scenario: Nick White is manager of Sports Store, Inc. Today he makes deposits into business account and his personal account. Amount exceeds $10,000. Correct answer for completing the CTR: Sports Store, Inc. info in 1st Section A, Nick White in section B. Nick White info entered again in second Section A.
I say that Nick White should be identified in Section A.1, conducted on own behalf in section B and Sports Store, Inc in 2nd section B. This was incorrect according to the online training.

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#1109166 - 01/12/09 05:07 PM Re: CTR completion nemsi
Georgia Plum
Unregistered

I would put Nick's personal info in first Section A and Sports Store, Inc. in second section A. You do not need two Section B's. Nick is the only one conducting the transaction so I would check conducted on own behalf (no need to enter any info on Nick in Section B.)

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#1109213 - 01/12/09 05:53 PM Re: CTR completion
nemsi Offline
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Joined: Nov 2005
Posts: 383
Thanks Georgia Plum. You would complete the CTR the same way I would complete the form. According to the training module I completed, we're both incorrect. Of course we know that we're not incorrect. Thanks again.

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#1109400 - 01/12/09 08:25 PM Re: CTR completion nemsi
E.E.G.B Offline
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E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
Sounds like the training is built upon the 2006 FinCEN interpretation of DBAs(which was revised in January of 2008 to be the way you and GAPlum want to do it.) The 2006 method would result in the answer they've got in the training. FinCEN says they'll accept both (but off the record they encourage you to move to the 2008 interpretation. However, I know for a fact JH Vertex does it the 2006 way.)
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#1109764 - 01/13/09 02:45 PM Re: CTR completion E.E.G.B
nemsi Offline
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Joined: Nov 2005
Posts: 383
Thanks EGB but can't use the 2006 FinCEN d/b/a interpretation for this scenario because the business is incorporated and Nick is an employee of the business- no ownership.

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#1109791 - 01/13/09 03:03 PM Re: CTR completion nemsi
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,786
Cape Cod
The CTR for Nick's deposits can be handled in one of two ways:

  1. Sports Store, Inc., in section A, front of form. Nick in Section B and in Section A, back of form.
  2. Nick in section A, front, with "conducted on own behalf" checked in Section B. Sports Store, Inc., in Section A, back of form.


When completing a CTR I always suggest using the option that is more efficient. One way to do that is to avoid listing a person more than once on the form. That rule of thumb makes option 2 above the better choice, in my opinion. But either option is correct.
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#1111891 - 01/15/09 07:59 PM Re: CTR completion nemsi
MoodyBlue Offline
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Joined: Jul 2006
Posts: 183
Below the Mason Dixon Line
What kind of online CTR training is available?? We have teller training coming up and may be interested in this. Thanks.

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