It was recently discovered that previously filed CTRs inadvertently did not include the DBA name. For example, it's Jane's Baskets LLC, DBA Janie's Cool Carriers. The CTRs were filed only with Jane's Baskets LLC as the name.

(1) Do we need to amend those CTRs to include the DBA name on it?

(2) If we do need to amend, how far back do we need to go? Back to when the account was opened or the past 12 months?

(1) Only FinCEN can give you dispensation to not amend. You will have to contact the help desk to request a determination.

https://www.fincen.gov/sites/default/files/shared/BackfilingandAmendingCTRs.pdf

(2) Figure out how far back the error goes and include that in your communication with FinCEN. They will tell you how far back you need to go.

Thank you.