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#2078892 - 05/16/16 08:42 PM CTR on a Corporation
speeks Offline
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Kansas
I have a question on a CTR for a Corporation.

Corporation made a deposit in cash over $10,000.00. The conductor of the transaction, happens to be one of the owners of the corporation.

On the CTR, we list the corporation as the entity Part 1, 2c, the conductor is the person actually making the transaction who happens to be one of the owners Part 1, 2a? Not sure on the 2a..... Do we need to do a page for each of the owners?

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#2078926 - 05/17/16 01:29 PM Re: CTR on a Corporation speeks
John Burnett Offline
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No, absolutely not. It helps to get away from the idea that you are reporting on who benefits from a transaction (in this case, the corporation's owners benefit only indirectly), and instead understand that you report "on whose behalf" the transaction is completed.

In your scenario, there will be two Part I sections of the report. The first, checking box 2c, is on the corporation. The second, checking box 2b, is for the individual conducting the transaction. There is no person conducting the transaction on his own behalf (2a) entry.
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#2078936 - 05/17/16 02:32 PM Re: CTR on a Corporation speeks
RockChucker, CAMS Offline
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Welcome to BankersOnline speeks!
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#2079124 - 05/18/16 01:10 PM Re: CTR on a Corporation John Burnett
speeks Offline
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Kansas
Thanks so much for the help!

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#2080429 - 05/25/16 08:20 PM Re: CTR on a Corporation speeks
BowlingQueen Offline
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Wisconsin
A similar question has come up in another banking forum. The question is related to a business customer with multiple authorized signers (who may or may not be "owners") and whether or not to include all authorized signers when filing a CTR. One of the responses given is that it is NOT wrong to include the business and all signers, as long as you are consistent in doing so.

My belief is that you file only on the business (person on whose behalf transaction is conducted) and the person(s) conducting the transaction. As John stated above, even if the signers are "owners", they only indirectly benefit from the transaction and the transaction is not conducted on their behalf.

I'm not sure how including all signers is providing useful information to law enforcement on people who played no direct part in the transaction.

Am I correct in my belief?
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#2080435 - 05/25/16 08:29 PM Re: CTR on a Corporation speeks
bcompliance Offline
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I think it would be a big waste of time ot include all owners/signers on the CTR.

When I do training on this with employees I try to get them to see who is the actual owner of the funds, which is the entity, not the owners of the enitity (plust the individual(s) conducting the transaction(s) like mentioned above).
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#2080440 - 05/25/16 08:36 PM Re: CTR on a Corporation speeks
BowlingQueen Offline
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bcompliance........that's exactly what I think! The one responder even said their examiners believe they SHOULD be included and I'm like "whaaaa? WHY?".
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#2080444 - 05/25/16 08:45 PM Re: CTR on a Corporation speeks
bcompliance Offline
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They need to tell their examiners to read the CTR Instructions and FAQ's!
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#2080449 - 05/25/16 08:56 PM Re: CTR on a Corporation speeks
John Burnett Offline
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It absolutely IS wrong to include the signers and the owners of the corporation, LLC, or other entity. They aren't persons on whose behalf the transaction is completed.
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#2080452 - 05/25/16 08:57 PM Re: CTR on a Corporation speeks
BowlingQueen Offline
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Wisconsin
I'll have to admit, I looked through the FAQs to see if I could find a better explanation as to why what they're doing is completely unnecessary and overkill but I couldn't find anything.
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#2080454 - 05/25/16 08:58 PM Re: CTR on a Corporation speeks
BowlingQueen Offline
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Wisconsin
Thanks, John! smile
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