Have a question about completing the new CTR Form.

Under the new form, are you required to identify the person making the transaction for a corporation.

If so, how? 2c is the only box that allows for the entity to be checked. Then where do you put the person name and their information?

Thanks for your help.

Yes you must identify them. Your will have multiple Part I's. Using 2c you will identify the corporation. Using 2b you will identify the individual(s) who brought in the cash.

Thanks Brian. Trying to make this harder that what it should have been. Again thanks for your help.

Don't worry Crash...I find myself shouting "WHERE IS SECTION B????"

Sorry this new form has me rethinking everything. What if you have a business entity with 2 partners. Only one brings in the transaction. Because all 3 benefit does that mean we need to list the other absentee partner?

The key word is "entity" The "entity" or partnership, corporation, LLC, etc benefits from the transaction(s) and you would check box 2c for the entity. The one partner who made the transaction would be 2b. The partner who did not make a deposit would not be included on the CTR.

(Similarly on the Legacy form, Entity is in Section A, and depositor in Section B. You would not list the partnership and both partners in Section A)

The rules haven't changed, just how we input the data.

Thanks for clarifying that. I do have one more additional question in relation to what we just discussed.

What is the purpose of Part I- 2b, line 21 and 22 being completed? Wouldn't this always match Part I-2c's?

bump

FinCEN is interested in breaking the dollars down by conductor and by person on whose behalf the transactions are completed.

Law enforcement wants to know who is bringing in the cash..it could be multiple persons on behalf of the same entity.

In your partnership example, if you have each partner bringing in a deposit (say one brings in $9,000 and one brings in $2,000.) You will have two Part I 2b listing how much each individual brought in, and one Part I 2c listing the full $11,000.

I was thinking this was only to show how much the individual in Part 1 2b was benfiting from the transaction.

For most of our business accounts this would be zero as they are just the conductor. So your explaination helps clarify. Lines 21 and 22 should always have a dollar amount based on who the conductor is.

For each person/entity listed in part I there should be a dollar amount listed in either 21 or 22 or both.

In my example for you.

John Conductor - Line 21 $9000.00
Jane Conductor - Line 21 $2000.00

Partnership - Line 21 $11,000.00

Brian-
I just need clarification on this sample you give-
We have a party store. The party store makes a night box deposit of 5,000 into 2 accounts. The owner also comes into the bank, later in the same day and conducts a transaction for the store, and deposits 5100 into a third account.


How would this be listed and what would be done with #24?

Thank you.

What's the type and amount of the transaction the owner conducts for the store?

they are deposits into his operating account, his lottery account, his ATM account. They vary in amounts regularly, but all accounts are in the name of the store.

How do you report a deposit into a trust account? Which box on 2a do I select for each?

I have a loan customer that made a large payment in cash (CTR required). There are other individuals on the loan that benefited from this transaction. Do I list an amount on line 21 for all of them or just the individual that presented the cash?

When completing part 1 for the corporation you enter the $ amount deposited and the account number. When completing part 1 for the person conducting the transaction for the corporation do you list the $ amount and account number again in his section?

Yes.