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#1780878 - 01/29/13 07:53 PM CTR - DBA
newbie4soul Offline
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On a CTR, if we are aware that the business customer uses a DBA name but it is not officially registered yet then is it incorrect to indicate that DBA name on the CTR?

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#1780879 - 01/29/13 07:56 PM Re: CTR - DBA newbie4soul
rlcarey Online
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uses a DBA name

What does this mean? How do they "use" a dba name.
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#1780882 - 01/29/13 08:00 PM Re: CTR - DBA newbie4soul
Dani York, CRCM Offline
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The CTR is to help law enforcement catch money launderers and terrorist financiers. If you know that the business is operating under a DBA, registered or not, law enforcement would probably find that information useful if they decide to investigate the business.

I would include the DBA name on the appropriate block on the CTR.
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#1780897 - 01/29/13 08:18 PM Re: CTR - DBA newbie4soul
newbie4soul Offline
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The registed entity name is 'Auto Body Shop's Inc.' on the business documents but the customer's business sign says 'John's Auto' and that's what the business is known as in the neighborhood but the customer did not register the DBA name.

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#1780902 - 01/29/13 08:21 PM Re: CTR - DBA newbie4soul
rlcarey Online
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I agree with Dani as far as CTR reporting goes, but there are issues far beyond that detail. Like are you accepting checks made payable to John's Auto" ?
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#1780918 - 01/29/13 08:31 PM Re: CTR - DBA newbie4soul
Elwood P. Dowd Offline
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Focus on your records. Does your bank know them by that name; i.e. do you let them deposit checks payable to "John's Auto?" Does your state allow DBA registration?
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#1780947 - 01/29/13 09:05 PM Re: CTR - DBA newbie4soul
newbie4soul Offline
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We only accept checks payable to 'Auto Body Shop's Inc.' and I'm being told to complete the CTR with two section As when filing a CTR on a legal entity operating under a DBA name. Am I supposed to check 'Multiple Persons' on the CTR?

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#1780953 - 01/29/13 09:14 PM Re: CTR - DBA newbie4soul
Elwood P. Dowd Offline
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I see no reason to include a DBA name when they are not registered to use one and it is not part of your relationship with the customer. Regardless, I don't really think it makes a lot of difference.

I cannot explain in detail how to complete the form because I do not know if you are using the legacy version or the Form 112. Either way, you only have one customer, the entity. If the entity did have a proper DBA name both forms allow for its use without treating it as a separate person (which it is not).

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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1780964 - 01/29/13 09:29 PM Re: CTR - DBA Elwood P. Dowd
newbie4soul Offline
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Thank you all.

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