We have a local Real Estate Closing Attorney who received a "reportable" amount of cash for a closing. I recall reading something from FinCEN that stated we needed to include the actual individual or entity that benefited from the closing on the CTR. In this case, the individual loaned the cash to a church for the closing. The closing Attorney sent the individual here to deposit the cash into the Trust Account. So who goes where? Do I list the Closing Attorney and Church as benefactors (Part 1 Section A) and the individual as the conductor (Part 1 Section B)?

Go here and scroll down to Administrative Ruling 89-5. Review Example #3. Get the lawyer to confirm your understanding of the facts then: the individual goes in Section A and you check "conducted on own behalf" in section B. Add another Section A for the church and one for holder of the IOLTA (lawyer or law firm). (Including the church is a judgment call on my part.)

Just in case someone wants to engage in an academic discussion about whether Administrative Rulings are still binding: When they are the only guidance available on a specific issue they are automatically the best guidance available.

It's also worth noting that this should have been figured out before the transaction was allowed to take place. I think it odd that an attorney is cagey enough to send someone else to deposit the cash to an IOLTA...lawyers don't do that. I would make it a point to tell him the reporting would include his name or that of the firm.