I agree - from the sole prop. guidance:
A sole proprietorship is a business in which one person, operating in his or her own personal capacity, owns all the assets and owes all the liabilities. Consistent with the definition of “person” in the Bank Secrecy Act’s implementing regulations, a sole proprietorship is not a separate legal person from its individual owner. Thus, when filing a CTR involving a sole proprietorship, financial institutions are required to complete one section ‘A’, containing the name of the sole proprietorship’s owner, the sole proprietorship’s DBA name, the owner’s social security number (“SSN”), home address, date of birth, and occupation. Only one section ‘A’ is required, even if the business operations have a different address and/or tax identification number (“TIN”) than its owner.
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