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#2242463 - 09/15/20 05:48 PM Trust Account CTRs
Compliance Slave Offline
Junior Member
Joined: Nov 2006
Posts: 39
Fresno, CA

I think we can agree that a Trust that uses an EIN should be listed as an Entity on the CTR form.

If a Trust uses the trustees SSN, is the Entity box also to be checked? It wouldn't seem to be appropriate but where would you put the name of the trust in the CTR if you don't select the Entity box? Field 8 "Alternate name"?

FinCEN isn't calling me back! Need some direction.

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#2243605 - 10/06/20 05:19 PM Re: Trust Account CTRs Compliance Slave
Debbie DeFur Offline
New Poster
Joined: Dec 2014
Posts: 4
We have submitted CTRs like your question with the trust name on line 8 (alternate name) and did not check the
"entity" box.

I have an additional question to this type of CTR though, The trust is in Edward's SSN but Edward is deceased. I'd like to know the answer as to listing a deceased person on the CTR. It doesn't make sense to list him, but I do not know how to proceed with the CTR.

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#2243641 - 10/06/20 07:45 PM Re: Trust Account CTRs Compliance Slave
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,593
Cape Cod
If Edward's SSN is being used by the trust after Edward's demise, you have a problem. If there is still someone alive with a right to revoke the trust, his/her SSN should be used. If the trust is no longer revocable, it needs its own EIN, and the bank should insist upon it when contacting whoever is the current trustee.

No one can use a deceased person's SSN for any purpose, other than to file the deceased's final tax return.
Last edited by John Burnett; 10/07/20 01:39 PM.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2243673 - 10/07/20 11:34 AM Re: Trust Account CTRs John Burnett
Debbie DeFur Offline
New Poster
Joined: Dec 2014
Posts: 4
Thank you so much for your help!

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