Skip to content
BOL Conferences
Thread Options
#2172292 - 04/06/18 03:15 PM CTR on UTMA, personal, and trust, oh my
Bec Offline
Diamond Poster
Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
This one seems complicated and I am not sure how to go about it.

We have a $20,000 deposit brought in by one person, Mr. Doe
$5,000 deposited into trust account A with Mr. Doe and Mrs. Doe as trustees
$5,000 deposited into UTMA account with CHILD 1 and Mrs Doe as custodian
$5,000 deposited into CHILD 2 owned only by CHILD 2
$5,000 deposited into CHILD 3 owned only by CHILD 3

For the CTR,
Part 1 (c) Trust ($5,000)
Part 1 (c) Mrs. Doe with both the trust account and UTMA deposits reflected ($10,000)
Part 1 (c) CHILD 1 ($5,000)
Part 1 (c) CHILD 2 ($5,000)
Part 1 (c) CHILD 3 ($5,000)
Part 1 (a) Mr, Doe with all accounts and all cash totals reflected. ($20,000)

Is that accurate?
_________________________
Go Packers

Return to Top
BSA/AML/CIP/OFAC Forum
#2172306 - 04/06/18 03:47 PM Re: CTR on UTMA, personal, and trust, oh my Bec
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
Based on the info you provided it sounds correct to me.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

Return to Top
#2172406 - 04/06/18 08:11 PM Re: CTR on UTMA, personal, and trust, oh my Bec
Bec Offline
Diamond Poster
Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
For what its worth, I did contact finCEN and they told me that I would not report Mrs. Doe as a beneficiary on the UTMA account since she is merely a custodian and does not benefit from any proceeds associated with the account and she did not bring in the money.
_________________________
Go Packers

Return to Top
#2172424 - 04/06/18 08:59 PM Re: CTR on UTMA, personal, and trust, oh my Bec
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
That makes sense, but it's in direct conflict with published advice they have given on other fiduciary relationships.

Point being: It really makes no difference.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z