I reached out to FinCEN early this week, but have had no luck hearing back from them.

We are in a community property state, so husband and wife can both own a sole proprietorship.

John's Business has its own EIN, John Smith and Jane Smith are both owners.

Jane Smith cashed a $10k check payable to the business against the sole prop account.

Jane Smith then withdrew $5k cash from her personal account.

How on earth do I do this CTR? Do I do two Section 1's with Jane Smith DBA John's Business and another as Jane Smith as herself? Or just one Section 1 with all of Jane Smith's info, except for the business name in the DBA section?

I am so confused.

Have you seen the (currently delayed and not yet required) FinCEN guidance for CTRs on sole proprietors?

https://www.fincen.gov/resources/st...gs/fincen-ctr-form-112-reporting-certain

I did, thank you. I might be having a hard time interpreting the guidance.

It seems like we would file to Part 1s, since Jane Smith is operating as a DBA and operating as herself. Does that sound right?

You cash checks made payable to a business?

Are you sure that your state allows two people to own a sole prop?

I'm also in a community property state, but here, that does not mean two people can both operate a "sole" proprietorship.

Sole = one individual

No such thing as a Dual Proprietorship