We have always included joint account holders when doing a CTR for cash withdrawals. With that being said, If a one account holders (person A) comes in and withdrawals $20,000 and then during the same day the other account holder (person B) comes in and withdrawals $100 cash out of an account that only has his name on it, would that cash withdrawal by person B be included on the CTR? If going by my initial thought I was going to file the CTR as:
Part I: Person A, Conducting transaction on own behalf - $20,000
Part I: Person B, Conducting transaction on own behalf- $20,100
Does that work?