Three payees on a check, (John, Joe, Jim) walk into a bank (sounds like the beginning of a bad joke). All endorse the back of the check-(from the sale of the deceased parents automobile,) which is split three ways by our staff (at the request of the Js) and the money is counted out, and equally divided into an envelope for each of them. The check is for more than the CTR limit but the split due each of the Js is not. Do we file a CTR? And if so, 3 part 1s, all "conducting on own behalf" of each of the Js?

Part of me says no . . . each J's portion was not over the CTR limit. But then on the other side of that . . . I can see where the government might want to know about 3 people coming in with one check and cashing it out.

I would vote no CTR. You don't have more than $10,000 by or on behalf of any one individual on one business day.

I called FINCEN and they indicate that a CTR would be required, as the intent of the check was that the check was made payable to all three Js (with and betweet in their names.) How they chose to divide the check up, was of no concern. Therefore each J would have a Part 1 for the full amount of the check.