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#1601626 - 09/09/11 03:06 PM CTR joint owners
Newly Southerner Offline
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ok so i have a two customers who has a joint account.

they both cashed a loan check that our bank issued to both of them.

the check benefited both of them so I have two section A. but what do I feel in section B? I can't choose conducted on own behalf because the loan check benefited both of the account holders.

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#1601632 - 09/09/11 03:10 PM Re: CTR joint owners Newly Southerner
PeeWee Offline
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Actually, you do check "conducted on own behalf" for the person whose information you fill in on Page 1, Section A. Be sure and check "Multiple Persons" at the top of the CTR. Then, put the second person's information on Page 2, Section A.

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#1601635 - 09/09/11 03:14 PM Re: CTR joint owners PeeWee
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PeeWee is right on the money.
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#1601638 - 09/09/11 03:15 PM Re: CTR joint owners Newly Southerner
Elwood P. Dowd Offline
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Agreed, but if I understand the fact situation, the CTR was generated by cashing an official check for two people.

The facts that they have an account or that the account is joint are not relevant.
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#1601683 - 09/09/11 03:41 PM Re: CTR joint owners Elwood P. Dowd
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I was at a BSA seminar yesterday and the guy told us that we will need Section A for all joint owners. Whether or not if the money is being benefited to all or one.

so say if John Doe comes to the bank and W/drawals or deposits 11,000 and the John Doe has three additional joint owners all those three joint owners will get a Section A.

and we would not select conducted on own behalf.

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#1601718 - 09/09/11 04:24 PM Re: CTR joint owners Newly Southerner
BrianC Offline
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If you do not check a box in Section B explaining why it is left blank, expect to receive the CTR back from the processing center. Section B cannot be left blank unless one of the boxes is checked, and in this case it would be conducted on own behalf.
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#1601736 - 09/09/11 04:46 PM Re: CTR joint owners BrianC
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ok this is what it says in FinCEN Form 104 (Eff. 03-2011)

Part I-Person(s) Involved in Transaction(s)

If an individual conducts a transaction on his own behalf and on behalf of another person(s), complete Section "A" for each person and leave Section "B" BLANK.

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#1601767 - 09/09/11 05:05 PM Re: CTR joint owners Newly Southerner
PeeWee Offline
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Keep reading the instructions...

Section B. Individual(s) Conducting Transaction(s) if other than above). Financial institutions should enter as much information as is available. However, there may be instances in which Items 15-25 may be left BLANK or incomplete. If Items 15-25 are left BLANK or incomplete, check one or more of the boxes provided to indicate the reasons.

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#1601774 - 09/09/11 05:10 PM Re: CTR joint owners PeeWee
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ok so im sorry to beat a dead horse, so I will have to choose conducted on own behalf to explain why section B was left blank.


then what the heck was the guy from the seminar talking about, confused the heck out of me!!
thank you so much!!

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