Court appointed Administratrix closes decedent's accounts and takes the funds in cash which aggregates over $10000. In completing the CTR info, the head teller, in Part I Section A, chooses the decedent as the "Benefactor"--(in our teller system)-- and in Part I Section B chooses "Own Behalf"

Since this is "CTR 101" we all know that a deceased person cannot benefit or conduct a transaction, and that the "Estate" should be reported in Part I Section A. However, as the bank has no estate account and therefore no EIN number, should the CTR be reported as

A. "John Doe Estate" and leave the Tax ID number blank----which will certainly be returned because the Tax ID number is blank.

B. Administratrix also reported in Part I Section A as well as Part I Section B

Thank you for your input.

P.S. My whole day yesterday was correcting almost every single CTR that tellers completed, bankwide, on Monday and now this one pops up. JOB SECURITY!!

You need to contact the Administratrix and get the required information.

Also, good luck if she ran off with the money as the estate is probably going to come after the bank. Estate monies should only be transferred into a properly established estate account or a cashier's check made payable to the estate should be given. Cash should never be given in a situation such as this. The bank is now squarely involved in this mess.

It's certainly not routine or even wise for an estate personal representative to withdraw cash from an account of a decedent. The account ought to have been converted to an estate account with an EIN or closed with a check payable to "estate of ______" instead of allowing the cash withdrawal.

But the horse is out of the barn.

The estate and the administratrix should be listed in separate Section A entries (no on can convince me a cash withdrawal of that size is not also done on behalf of the administratrix). "On own behalf" should be checked to indicate one of the Section A parties (the one that's alive) conducted the transaction.

As for the entry for the estate, indicate that there's no TIN.

I have a call into FinCen.

Supervisor told me to file the CTR either in the deceased persons name using the SSN and the Administratrix's name OR in the Administratrix's name only, which is not correct.


As for getting the required info, the CSR (an owner) replied that the Administratrix did not apply for an EIN for an estate as there is no estate and the funds are being used to pay for funeral expenses.

As for indicating that there is no TIN, the software that we use requires the Tax ID field to be completed---no "NONE" or "0's" etc...----otherwise the status of the CTR goes into a "Failed" status and cannot be E-filed or printed.