We have an account that is styled and titled as a sole proprietorship. The business actually incorporated a few years ago, yet the account documents were never updated. We have loans in the name of the corporation, but not the DDAs. I now have a reportable transaction and am questioning how the CTR should be filed. Should I list both the corporation (the true affected entity) and the proprietorship on the CTR? If so, how do I show the dollar amount to keep it from looking duplicated?

We just discovered this at our bank as well and have been filing CTRs with an incorrect name. FINCEN replied with the below....File under the legal name filed with the state office.


Per section “9. Corrected or amended reports” on page 86 (95/110), filers are informed that a corrected report must be filed whenever errors are discovered in a previously-filed FinCEN CTR (or any other FinCEN form). Amended CTRs must be filed whenever additional data about transactions are discovered.

Please determine: (1) the date the corporation’s name was changed, (2) how many CTRs would need to be corrected and (3) the date range(s) in question (i.e. 50 CTRs in 2017, 250 CTRs between 2015 – 2018). If 100 or more CTRs require corrections, please reply accordingly as the completion of a checklist for a determination may be required.

Based on the information provided in the checklist, a decision will be made and the filer (requestor) will be informed if those CTRs would need to be corrected. They would be given additional instructions on how to proceed with those CTR filings. Please keep in mind that a determination can take several months.

If the number of affected CTR does not require a formal determination, meaning that less than 100 CTRs are in question, the financial institution would need to proceed in submitting those corrected filings immediately.