I have a question about filing a CTR. I know this is a simple question but I am going to ask anyway. If a person deposits cash over $10,000 into his business account under a EIN number and comes back on the same day and makes a cash deposits under $10,000 to his personal account with his social security number, do you file a CTR for the combined amount or only on the business since it was over $10,000.

I have just started at this bank and the person before me told the tellers they would file a CTR for the combined amounts. I say you do not since it involves separate EIN/SSN numbers.

Am I correct?

Thanks for your help

If you have knowledge, you aggregate and report on all cash deposits conducted by the individual. We report on cash deposits over $10k "by or on behalf of..."

The amounts must be added together because the same person brought in both deposits.

So would you file under the individual name for the combine amounts or would you do this under the business? If the business was incorporated would that make a difference?

Transactions were conducted on behalf of both the business and all owners of the personal account(s) involved. Check "conducted on own behalf" for conductor.

Example:

$10,000 cash deposit to Acme Car Wash, LLC
$200 cash deposit to account of Joe or Betty Jones

Check "multiple persons" in 1B but NOT in Section B since you know who conducted all of the transactions involved. Check "multiple persons" also.

Identify Acme, Joe AND Betty in Part l: Section A.

Check "conducted on own behalf" in Section B.

Cash In Amount: $10,200
Item 34: Deposit
Document each account affected in Item 35.

Both, you will do multiple tranasactions and multiple persons. Comes to two pages.

What is the business form? If it's a sole proprietorship, you can report with one section A entry in the owner's name, using his SSN and address, inserting any DBA name in item 5. Then check "on own behalf" in section B.

If the business is an LLC or corporation, fill in Section A on the front for the individual, checking "multiple persons" and "multiple transactions." Check "on own behalf in Section B. Then complete a second Section A entry (on reverse) for the business. Combine the cash in amounts in item 26 and list both account numbers.

Good point, John. I made an assumption the business was a legal entity because of the reference to the EIN, but that may not be the case. Never assume!

Thanks for all your help. This helps tremoudously.

Thanks again