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#16921 - 05/06/02 07:36 PM CTRs and DBAs

Trying to get a consistent solution to this issue is quite complicated, but I thought I'd try one more time...
If a sole proprietor opens an account for his business using his SSN, and deposits made that day exceed the CTR threshold, how would you complete the benefactor's section of the CTR form?

1. I've been told by some that the primary benefactor is the individual with their personal information, and on the second page of the form you should list the individual's name, the DBA, and the business address.
2. Others have told me you should list the individual's name, the DBA, and individual's personal information in the primary benefactor's section with nothing on the second page.
3. Still others have said the business information should go on the first page, and the owner should be listed as the transactor - what if they didn't make the deposit?! AAAUUUGGHH!

If someone can shed some light, or preferably provide some document reference (other than the instructions on the form itself which do absolutely nothing at providing "the rule" to follow), I would be forever in your debt!!!

Anguished in Alabama

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General Discussion
#16922 - 05/06/02 07:51 PM Re: CTRs and DBAs
BrendaC Offline
Power Poster
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I called FinCEN to obtain directives after receiving conflicting information. I was told that we should thoroughly identify the sole proprietor in Part 1, Section A by completing the CTR as a multiple-person CTR benefiting the proprietor as an individual (SSN, DOB, home address and ID) and as a business (EIN or SSN, business address). It was explained to me that this applies to sole proprietors because they have never formally separated their personal and business identities. Whether the individual and business information is on front or back in Section A is of no consequence as long as it's all in Section A.

Section B should truly reflect identity(ies) of individual(s) conducting transaction(s), if known.

P.S. We should also include in the CTR any cash activity in the personal accounts of the sole proprietor as well as the business. Most of our aggregation reports will catch this if we have set them up correctly. The IRS really helped us here by revising IRS forms to tell us they prefer we use the sole proprietor's SSN.
Last edited by Brenda Canterbury; 05/06/02 07:53 PM.
Life without Jesus is like an unsharpened pencil - it has no point.

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#16923 - 05/06/02 07:51 PM Re: CTRs and DBAs
NancyF Offline
100 Club
Joined: Dec 2001
Posts: 173
I have always put the individual's name in Part I, section A, line 2, with the DBA on line 5. I use the business address, assuming it is different than the individual's home address. I put the individual/owner's name in Section B, person conducting the transaction with his home address and identification info. If someone else performs the transaction (such as an employee), their name, address and ID would go in Section B.

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#16924 - 05/06/02 08:01 PM Re: CTRs and DBAs
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
Is the business a legal entity, or does it exist in name only? If it is nothing more than a trade name, then I do not see how the name could be listed as a beneficiary, therefore I would advise option # 2. Kirchman explains it this way: 'If the conductor is conducting the transaction for his or her sole proprietorship, which has a DBA, then he or she is benefitting from the transaction, and the information should be recorded in section A, and the DBA is recorded in item 5.'

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#16925 - 05/07/02 12:40 AM Re: CTRs and DBAs

I do mine the way Nancy F does. I began doing them that way in 1994 after calling the hotline. I have never had a problem.

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