Jane Doe makes the following transactions on one business day:
(1) Deposit of $8,000 cash on behalf of John Doe DBA John's Garage.
(2) Deposit of $7,000 cash on behalf of John Doe DBA Doe's Transportation.

Do we list John Doe twice in Part 1 (once for DBA John's Garage and once for DBA Doe's Transportation) as conducted on behalf of? I know the rule is to not list someone twice on a CTR, but is this the same person or two different DBAs that need listed seperately?

There is only one person involved here: John Doe. There are multiple DBA's, but the CTR, unlike the SAR, only facilitates the listing of one DBA name.

When I called the Helpline on this issue I was told to list as many of the DBAs as would fit on the form, separating them with a comma. You may want to make the same call and document the response.

Comma? One of my clients was told semi-colon..... Auditor K - When you call, let us know to break the tie

We have a similar customer (business) that has 2 DBAs.. We seperate our DBAs with a /.

Entity Name: Business LLC

Alternate Name: Corner Store/Gas Station


I guess we are doing it wrong? I am also interested in what they say.

As Randy suggested, someone might want to call for the tie-breaker. I've already called once...

Ok, here is the tie breaker. Spoke to FinCEN yesterday and they informed me that it is up to the institution to decide for their own policy if they will put one DBA name or all DBAs in the case of multiples under the same Sole Proprietor. (Whichever they decide to make policy they must be consistent in their filings.) Then if they have more then one DBA associated with the sole proprietor on line 8 of the CTR, they must be divided by a semi-colon!

Thank you.

I'm increasingly fond of saying: Any focus on the minutia of CTR completion is simply about avoiding picayune regulatory criticism. There are no universal truths in the completion of any of the reports. There is perusing the instructions or obtaining guidance from FinCEN; documenting it; doing what you were told; and going on to what's next.