Assume the following scenario:

Jane Doe deposits $6,000 cash to the account of XYZ Company, $3,500 cash to her personal account, and $2,000 cash to her mother's account. XYZ Company is exempt from CTR reporting under the Phase II rules.

Do I need to still do a CTR since one person (Jane Doe) came in to the bank with more than $10,000? If so, does XYZ Company still get listed in Section A?

Although I'm no longer a BSA Officer, at my previous bank we would. Jane is not exempt so her transactions are reportable.

Because XYZ Company is exempt from CTR filing, you ignore the deposit to its account (as if it didn't occur). That leaves you with Jane Doe transacting cash-in activity totaling $5,500, so you do not file a CTR.

No CTR is required if the cash deposited to the business account is exempted (and, therefore, removed from the aggregate total). Whether it should be reviewed for possible suspicious activity reporting is another issue.

Interesting. I would have been in the same camp as Duchess Skittles. Since the CTR was being filed because of Jane bringing in more than $10,000 (and Jane isn't exempt), I would have filed.

FWIW - for peace of mind - you might want to check with your regulator. I know the FDIC from Atlanta also agreed with what I stated. I know - regulators should always agree, but we know they don't.

I would have leaned towards filing as well, my focus being on Jane, and not so much the beneficiaries in this situation, since there are multiple ones.

I'm surprised I got such varying responses to this. We have a few that say "no CTR necessary" and a few that say "yes a CTR is required". Is the best bet really to go to our primary regulator for the "their" answer?

That transactions on the exempt account are exempt as John indicated and it is if they didn't happen. There is no CTR required.