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#2146940 - 09/20/17 11:01 PM CTR Exemption for Sole Proprietor
RiskyBusiness Offline
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Joined: Sep 2010
Posts: 28
Way past 5 o'clock and I can't think straight! Can we consider a Phase II CTR exemption for a DBA account?

Customer is a sole proprietor who owns a small grocery. Account is a business checking product type. Account is set up under owner's SSN. Does not have a separate EIN.

Long time customer whose activity meets all the other exemption criteria. I'm just hung up on the ownership aspect.

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#2146942 - 09/21/17 02:23 AM Re: CTR Exemption for Sole Proprietor RiskyBusiness
BrianC Offline
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Joined: Nov 2004
Posts: 6,067
Exempting a sole proprietor's transaction accounts (checking and money market) is permissible. The challenge is demonstrating that the business is organized within a state since a sole proprietorship does not have to register with the Secretary of State.

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#2148225 - 09/30/17 01:34 PM Re: CTR Exemption for Sole Proprietor RiskyBusiness
Elwood P. Dowd Offline
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#2162257 - 01/29/18 06:59 PM Re: CTR Exemption for Sole Proprietor RiskyBusiness
MBTCompliance Offline
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Joined: Apr 2015
Posts: 337
To document the sole proprietor's business is a "bona fide business", could we use a business license (if they have one), documentation where they are licensed to sell lottery tickets with the state, or state sales tax payment records?

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#2162260 - 01/29/18 07:14 PM Re: CTR Exemption for Sole Proprietor RiskyBusiness
rlcarey Offline
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Posts: 77,548
Galveston, TX
If you think that is: " Is incorporated or organized under the laws of the United States or a State, or is registered as and eligible to do business within the United States or a State", then go for it.

But the question remains, since there is no separation between the individual and their "dba" - how do you make sure that any cash deposits or withdrawals are related to the business??
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