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#1965451 - 09/29/14 06:48 PM How to file CTR?
Huskers:) Offline
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Joined: Oct 2010
Posts: 9
Individual A comes in to bank and withdrawals $12,000.00 out of a joint account. Leaves bank. Some time later (on same business day) Individual A comes back in to bank and deposits $13,000.00 into a corporation account of which she is a signer.

How should I fill out CTR?

CTR #1 Individual A as "person conducting transaction on own behalf" and Individual B (on joint account) as "person on whose behalf transaction was conducted" of $12,000 cash out.
CTR #2 Individual A as "person conducting transaction for another" and corporation "as person on whose behalf transaction" was conducted of $13,000 cash in.

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#1965460 - 09/29/14 06:59 PM Re: How to file CTR? Huskers:)
Matt_B Offline
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A CU, Where Regs Don't Apply
I don't think that would be wrong, assuming you're aware that individual B on A's joint account also benefited from the withdrawal. Otherwise, I'd file the same way.
Someone's about to get horned!

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#1965465 - 09/29/14 07:07 PM Re: How to file CTR? Huskers:)
BuckDog Offline
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One CTR. One person conducting all transactions.

My understanding is that you only put the person conducting the transactions on the CTR one time and mark "conducted on own behalf" And unless you know that the joint owner benefited from the transaction you don't put that person on the CTR.

One section with name of individual withdrawing $12,000 marked "person conducting on own behalf". Another section marked "person on whose benefit transactions was conducted" containing the information for the corporation. Totals would have $12,000 withdrawal and $13,000 deposit.

Last edited by BuckDog; 09/29/14 07:09 PM.
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#1965495 - 09/29/14 07:54 PM Re: How to file CTR? Huskers:)
John Burnett Offline
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John Burnett
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Cape Cod
BuckDog: It is perfectly acceptable (see question 24 in FinCEN's FAQ on CTR filing at to include the joint account owner as a person on whose behalf the withdrawal was completed, even if you know for a certainty that the withdrawal was not completed on his/her behalf.

Otherwise, I agree with your answer. One CTR because there was one individual conducting both transactions.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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