FINCEN came out with guidance on 1/25/2008, Ref # FIN-2008-R001 that dealt with a couple ways to complete a CTR for sole props with and without separate TINS/EINS for the owner/entity.
Does this guidance still hold or did FINCEN come out with other guidance that replaced this one?
We are seeing in some training materials from a consulting firm that we should not check the "if entity" box if the person is a sole prop.
Thanks,

FinCEN CTR FAQ #26 provides examples of how to complete and notes that FIN-2008-R001 is the most current guidance.

https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr

Example #2 provides an example that matches your consultant's training. Do not check "if entity" enter all of the proprietor's info and enter the alternate name into the appropriate field.

FinCEN issued two pieces of guidance. The first was simply wrong; a sole proprietorship is not and never will be a legal entity. It is an individual. However, simply saying "We screwed up!" comes hard to any government agency. They left compliance with the first guidance as an option, but taking that approach really confuses bank employees who actually know what they are doing.