An escrow agent for a title company makes a cash deposit for $22k to the company escrow trust account. The funds are from three of their clients and each gave the escrow agent less than $10k. Do we report the information on the escrow agent's clients as the person on whose behalf the transaction was conducted, in addition to the title company? I've seen a lot of reference to IOLTA accounts and completing CTRs but not for escrow trust accounts, but it may be a similar thought process.

IMO the CTR would be filed similar to an IOLTA account and you would need all identifying info on the 3 clients as well as the title company.

^^^^ What devsfan said.

I spoke with two different people at FinCEN who stated we would need the information on the title company clients and the third time we called FinCEN, the third person said we only would need the information on the conductor and the title company

Why would you call FinCEN three times on the same issue unless you were shopping for an opinion???

Thank you for your as always helpful opinion rlclarey. Like a large amount of people in the AML industry, I have had incorrect information from FinCEN. I received the first response based on my call, and then a second response when I called for a CTR backfiling determination. The third time was legal sending a letter which generated the third response.