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#2041172 - 09/29/15 03:10 PM CTR for signer on LLC
SmallBank2 Offline
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SmallBank2
Joined: Feb 2014
Posts: 32
We have an LLC and the signer cashed a $40,500 made payable to himself indicating in the memo of the check "2008 Pick Up". The Lead teller filed the CTR indicating the signer as transacting on behalf of another and the LLC as the person on whose behalf the transaction was conducted. Am I just being foggy in the brain or should this have just been only the signer as person conducting transaction on own behalf since the check was made out to him personally? Or - if he had indicated to the teller it was to purchase a truck for the business, how it was filed was appropriate?

Previously, same signer used a counter check made payable to the business from the business (I know, I know - new teller) and the Lead Teller filed the CTR as the signer as person conducting transaction on own behalf since he was the person obtaining the cash (The memo on that check stated Bobcat - this is a lawn service.)

I'm looking to establish consistency in the filings so input would be appreciated!

... Feels like Monday.

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#2041182 - 09/29/15 03:39 PM Re: CTR for signer on LLC SmallBank2
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The key is for your staff to ask whether the transaction is on behalf of the business or the individual. Each of those transactions smacks of a business purpose, so my tendency, absent any info to the contrary, would have been to file each of them as having been conducted on behalf of the LLC by the individual.
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#2041196 - 09/29/15 03:53 PM Re: CTR for signer on LLC SmallBank2
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Agreed. Your choices are a) ask or b) guess.
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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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