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#2131604 - 05/23/17 11:07 PM 2 Businesses-2 Transactors 1 CTR
Bec Offline
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Bec
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Posts: 1,114
The Great White North
Just need someone to confirm or correct my thinking on this one.

Transactor 1 deposits $8,000 into Business A and $1,098 into Business B
Transactor 2 deposits $10,000 into Business A

CTR should be filed on Business A with Transactor 1 and Transactor 2 listed.
Business B should not be entered on the CTR with the $1,098 transaction correct?

Thank you
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#2131641 - 05/24/17 01:53 PM Re: 2 Businesses-2 Transactors 1 CTR Bec
DoS Offline
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one state over
I agree, that is how I would do it
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#2131693 - 05/24/17 04:06 PM Re: 2 Businesses-2 Transactors 1 CTR Bec
RockChucker, CAMS Offline
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The Country
Bec, it sounds like you would file it the same way I would too. By or on behalf of really helps clear this one up.
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#2131945 - 05/25/17 05:00 PM Re: 2 Businesses-2 Transactors 1 CTR Bec
JennKK2 Offline
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i agree. this is how I would complete the CTR
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#2132075 - 05/26/17 02:00 PM Re: 2 Businesses-2 Transactors 1 CTR Bec
WonderWoman Offline
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gone fishin'
I agree that's how I thought I would do it too - but I got a different response from FinCEN.

"FinCEN does not require the FI to identify the conductor for low dollar amounts. However, many institutions have systems in place to capture this data at the time of deposit just in case the aggregated transactions exceed the threshold. If the information is captured, then FinCEN expects it to be reported."

Per the FinCEN rep, "once any business entity has been captured on a CTR, the FI is required to aggregate and report ALL additional cash transactions transacted on the same business day, regardless of the conductor. Her specific guidance to the below scenario:

1. John Doe conducts the following transactions simultaneously that total $11,500
a. $4,500 cash deposit to benefit ABC Corp (EIN #12-3456789),
b. $4,000 cash deposit to benefit MNO, LLC (EIN #98-7654321),and
c. $3,000 cash deposit to benefit XYZ & Associates (EIN #34-5678912)
2. CTR is created for $11,500 with John Doe as conductor and the three business entities are identified as benefiting from the funds deposited
3. Later the same day, Michael Smith conducts the following two transactions simultaneously that total $750
a. $500 cash deposit to benefit ABC Corp (EIN #12-3456789), and
b. $250 cash deposit to benefit XYZ & Associates (EIN #34-5678912)

 Part I for John Doe ($11,500) – 2b. Person conducting transaction for another
 Part I for Michael Smith ($750) – 2b. Person conducting transaction for another
 Part I for ABC Corp ($5,000) – 2c. Person on whose behalf transaction is conducted
 Part I for MNO, LLC ($4,000) – 2c. Person on whose behalf transaction is conducted
 Part I for XYZ & Associates ($3,250) – 2c. Person on whose behalf transaction is conducted
 Part II #25 Total Cash In - $12,250"
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#2132085 - 05/26/17 02:27 PM Re: 2 Businesses-2 Transactors 1 CTR Bec
Daisy Doodle Offline
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Southern U.S.
Back to the OP's scenario though, I think the question involved the deposit to Business B--if it needed to be included on the CTR. FinCen's response addressed all deposits to the SAME business.

Transactor 1 deposits $8,000 into Business A and $1,098 into Business B
Transactor 2 deposits $10,000 into Business A

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#2132108 - 05/26/17 03:18 PM Re: 2 Businesses-2 Transactors 1 CTR Bec
WonderWoman Offline
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WonderWoman
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Posts: 2,108
gone fishin'
No - these were all different businesses. Not one business went over $10k in each account. Only one conductor had over $10k.
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#2132242 - 05/26/17 08:42 PM Re: 2 Businesses-2 Transactors 1 CTR Bec
John Burnett Offline
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John Burnett
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The key to the OP is that the bank knows who the transactors were. Ergo, they needed to include them in the filing. If they didn't know, because no one thought to get the information (each Business A deposit was under the reporting threshold), they would not have to include transactor info; they could check the aggregated box and be done.
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#2132249 - 05/26/17 08:58 PM Re: 2 Businesses-2 Transactors 1 CTR Bec
WonderWoman Offline
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WonderWoman
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gone fishin'
Yes, but do you also include Business B? FinCEN says I have to. Doesn't quite make sense.
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#2132371 - 05/30/17 06:03 PM Re: 2 Businesses-2 Transactors 1 CTR Bec
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,868
Cape Cod
I think that FinCEN misunderstood what was being asked. The two deposits to Business A get reported (with the transactor information IF YOU HAVE IT). The deposit to Business B does NOT get reported. Business B did not have more than $10,000 in cash transactions completed on its behalf, and the transactor of the Business B deposit did not transact more than $10,000 in cash transactions.
Last edited by John Burnett; 06/02/17 03:17 PM. Reason: "yet" ==> "get"
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