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#1828076 - 06/26/13 09:59 PM CTR - to file or not to file
Tryin-2-Comply Offline
100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
We have a relationship with a customer who is husband and wife - they are the managing members of an LLC. She withdrew $9,300 from their personal account and at the same time withdrew $1,100 from their LLC account (which operates under a seperate EIN). She received all the funds at the same time. Should a CTR be filed?

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#1828078 - 06/26/13 10:01 PM Re: CTR - to file or not to file Tryin-2-Comply
BrianC Offline
Power Poster
Joined: Nov 2004
Posts: 6,272
Since a single individual received more than $10,000, yes, a CTR is required.
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!

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#1828132 - 06/27/13 01:20 PM Re: CTR - to file or not to file Tryin-2-Comply
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,627
Cape Cod
And that would be true whether the withdrawal from the LLC was completed on behalf of the LLC or on her behalf. The deciding factor for filing is that the transactions were both completed by the same individual on the same business day.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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