Has there been any recent (last few years) guidance for completing a CTR for a trust? I have searched here, and only see old threads referencing the 1995 FinCEN guidance. For a family trust using a grantor's SSN, we are still completing multiple Section As for the trustee and trust. For an irrevocable trust using a separate EIN, should we do the same or only one Section A for the trust?

For the benefit of others, the September 1995 Guidance says:

23. Question: How should trusts and other third party accounts be reported?

Answer: If Jane Doe, the trustee of the John Smith Trust, makes a reportable deposit to the Trust Account, information on Jane Doe, the trustee, including the method used to verify her identification, must be entered in Part I, Section A. Identifying information on the John Smith Trust, who is the beneficiary of the transaction, must also be reported in a separate Section A (on the back of the CTR Form). However, if the transaction is conducted for Jane Doe, the trustee, by her secretary, then in addition to identifying Jane Smith, the trustee, and the John Smith Trust, the beneficiary, in separate Section As, the secretary, who actually conducted the transaction, must be identified in Part I, Section B.

The interpretation is that the transaction is on behalf of the fiduciary in addition to the trust. (The reference to "other third party accounts" is meaningless to me.)

That interpretation indicates a fundamental lack of understanding of the role an individual plays when he acts in a fiduciary capacity. (If I am only the trustee, I derive no benefit from depositing more than $10,000 in cash to a trust. If I'm also a beneficiary? Maybe.) FinCEN was similarly confused about the practical implications of sole proprietorships, but at the end of a series of interpretations eventually published instructions on CTR completion that reflect the reality of the situation. Unfortunately, no such evolution has occurred here.

Regardless of whether the trust is revocable or irrevocable, the only available guidance indicates that the transaction is on behalf of both the trustee and the trust and that both should be listed on the report.

Dusting off this old thread for a moment to hopefully get a point of clarity I did not see anything updating the 1995 guidance.

Using the logic above, if I had a situation where I was filing a CTR on a revocable trust in which there were two trustees (John Doe and Jane Doe, Jane Doe conducted the transaction) the CTR would be completed in this manner:

Part I (c) Trust
Part I (c) John Doe
Part I (a) Jane Doe

When completing the Part Is on the trustees do we put "Trustee" anywhere? Perhaps on the alternate name field as John Doe, Trustee?

For what it is worth, I contacted FinCEN to see what they had to say as far as CTR completion on a trust.
In the scenario above they said:

Part I (a) Jane Doe as beneficiary of the funds because she is the trustee and put the name of the trust in the alternative name field.