I have a reportable CTR on new accounts-----
A Convenience Store LLC has one operating account and has multiple DBA accounts set up for each store under the LLC. Each store deposits into their DBA account and then the funds are swept into the operating account nightly.

Part I Section A --LLC

Part I Section B --Report each Transactor

Part II --Aggregad amounts of all of the stores and list each stores account number

OR

Part I Section A --Multiples persons listing the LLC plus each DBA

Thanks!

I would say...

LLC Section A- Box 2
DBA Section A- Box 5-13
Section B- Report the transactor for DBA

I would also report each DBA on a seperate CTR. The only difference I would make would be if the DBA's did not have their own EIN.

That is me though...

I would also report each DBA on a seperate CTR.

I disagree, even whether or not each DBA had a separate TIN. There is only one entity here. I would list the multple DBAs in separate Section As.

This is how I printed the CTR but I started doubting myself and wanted to ask the advice of BOLers.

Thanks!!

What about the problem some people using e-filing have with trying to identify the same person (the LLC) more than once on a single CTR?

I would call FinCEN at that point of time, as this is a limitation imposed by their software and not the banks. It is really just my opinion that you would list each dba - I have never really seen any specific guidance. But I do know that aggregation under the LLC is most definitely required.

A-men to that, Randy. And for the record, I don't disagree with the way you'd complete the CTR. ..

Frankly, I think the CTR process is busted. It's just not set up to handle challenges like this scenario. So you have to do the best you can given the parameters available.

I don't really understand what the benefit would be in documenting all the DBA information. At the end of the day, it is all one company. If all the monies have been aggregated and reported, that should be sufficient.

But I know the instructions reference the DBA info. I called FinCEN about this years ago and was told just to document one DBA if the businesses were similar (such as all convenience stores). If any were different (such as a shoe store) I should list that one as well. Makes no sense, but I did it that way since it simplified the process when reporting for one corporation with 16 DBAs (all convenience stores).