Our Financial Institution just opened a Benefit Account under the FI Tax ID. If the FI receives cash under this account is a CTR triggered since FI's are exempt? The money will eventually be distributed to an organization that it was intended.

I guess the question that has to be asked is, "Why was the account not opened in the name of the organization using their Tax ID?" Stepping aside from the CTR question, this type of arraingment could also circumvent the CIP process and could be opened to critism.

Since the FI is not benefitting from the deposits, I would argue that this is not a Phase I exemption and that reportable deposits should be filed on a CTR listing the organization in Section A (Legacy Form) or 2c "Person on whose behalf transaction was conducted" (Form 112) and then the info on individual(s) making the deposits in Section B (Legacy form) or "2b Person conducting transaction for another" (Form 112).

Eevn if the bank has agreed to accept donations on behalf of the organization, the organization ultimately benefits.

Also, unless the FI is approved to operate under trust powers, this account has a lot more problems associated with it. If they do have trust powers, then they should already have procedures to deal with this.

As suggested, make certain your bank is empowered to act as a fiduciary...without that power there are no CTR issues to discuss. AFter you've done that, please tell us a bit more about the fact situation and we will try to help.

When in doubt, file the form, but the issues regarding trust powers are far more critical.