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#2243258 - 09/29/20 03:52 PM
Re: CTR for entity with multiple accounts
Barbl
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Power Poster
Joined: Nov 2004
Posts: 6,840
Illinois
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The rule that was effective on September 1st says that multiple Part I's are required if multiple "roles" in item 2 apply.
So if I make a deposit to my personal account (conducted on my own behalf) and I make a deposit to my business account (conducted on behalf of another) then I would have two part I's (2a and 2b).
In your scenario, the business had all of the deposited to its various accounts conducted on its behalf (item 2c) so there would only be one part I for the business with all applicable amounts and account numbers listed. Similarly there would only be one part I for the person making the deposits on behalf of another (Item 2b).
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#2243260 - 09/29/20 03:55 PM
Re: CTR for entity with multiple accounts
Barbl
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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FinCEN suspended its FIN-2020-R001 ruling and its changes to the filing requirements for sole proprietorships and legal entities.
But I don't think your question is affected by that ruling, anyhow.
As you describe it, one conductor makes cash deposits into multiple accounts of the same entity totaling over $10,000 in cash. You don't say anything about multiple locations or multiple DBAs of the one entity.
Let's say the deposits are $3,000 each into four accounts of the entity.
You would have one Part I section for the conductor and one Part I section for the entity.
The info on the entity would include its headquarters address and its EIN and identification information, along with any contact into (phone number, email address) for the entity.
You would include each of the four account numbers and the full $12,000 amount in item 21, and check the multiple transactions box (item 3), and box 2c.
Last edited by John Burnett; 09/29/20 04:00 PM.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#2243269 - 09/29/20 04:21 PM
Re: CTR for entity with multiple accounts
Barbl
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Power Poster
Joined: Nov 2004
Posts: 6,840
Illinois
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The role is the same. The transactions are conducted by the person (item 2b) on behalf of the entity (Item 2c). If the cash out also exceeds $10,000 then you can list the applicable account numbers and amount for cash out in Item 22 on the same Part I.
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#2243494 - 10/01/20 10:02 PM
Re: CTR for entity with multiple accounts
Barbl
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Member
Joined: Jun 2015
Posts: 58
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Does someone have a link to guidance on this new rule? my understanding is the rules were postponed indefinitely and we have not received or seen anything saying different. Thank you
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#2243516 - 10/02/20 06:04 PM
Re: CTR for entity with multiple accounts
Barbl
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Gold Star
Joined: Mar 2018
Posts: 374
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#2243523 - 10/05/20 01:37 PM
Re: CTR for entity with multiple accounts
Barbl
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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We should remember that, if and when FinCEN lifts the suspension of FIN-2020-R001, there may be changes prompted by comments and questions raised before the suspension was announced. We will be watching for any movement on the ruling here at BOL and will include any news in our Top Stories and Daily Compliance Briefing.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#2243539 - 10/05/20 04:57 PM
Re: CTR for entity with multiple accounts
Barbl
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Power Poster
Joined: Sep 2010
Posts: 2,670
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I agree, John, that there very well could be changes due to the questions raised before the suspension was announced. It will be interesting to see what they do.
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Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2244409 - 10/21/20 04:22 PM
Re: one conductor depositing into multiple businesses
Barbl
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Power Poster
Joined: Nov 2004
Posts: 6,840
Illinois
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Multiple part I's for the same person apply if they have different "roles" in the transaction(s). Since the person's role in all the transactions is 2b, then only one part one is needed. If the person had also deposited funds into their personal account, we would have needed an additional part I for them using role 2a since they conducted a transaction on their own behalf.
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#2257556 - 08/03/21 01:21 PM
Re: one conductor depositing into multiple businesses
Barbl
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Diamond Poster
Joined: Sep 2014
Posts: 1,309
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We have a hotel holding company that deposits funds for 4 different hotels into the same account. Each hotel has a different address, but the only address we have on file is the holding company. Each deposit slip lists which hotel the funds came from. In this scenario, I am assuming we only file one Part I for the holding company and all cash deposited into their one account? Since we do not have an account for each hotel location/entity I do not think it should be broken out into multiple Part I's. Thoughts?
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#2257558 - 08/03/21 01:29 PM
Re: one conductor depositing into multiple businesses
Barbl
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10K Club
Joined: Jul 2001
Posts: 84,344
Galveston, TX
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Depends on if the separate hotels are actually separate entities. If they are, then this account arrangement is likely not set up correctly.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2257567 - 08/03/21 03:05 PM
Re: one conductor depositing into multiple businesses
Barbl
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Diamond Poster
Joined: Sep 2014
Posts: 1,309
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After some clarification from our commercial lender, there are 2 real estate holding companies that each own 2 of the hotels, the deposit account is the operating entity
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#2257588 - 08/03/21 06:37 PM
Re: one conductor depositing into multiple businesses
Barbl
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Gold Star
Joined: Feb 2013
Posts: 460
Cape Cod
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So, for example, REIT A owns Hotels A and B and REIT C owns Hotels D and E, but Entity F (an LLC or a corporation) operates all four hotels?
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#2257589 - 08/03/21 06:38 PM
Re: one conductor depositing into multiple businesses
Barbl
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Gold Star
Joined: Feb 2013
Posts: 460
Cape Cod
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Do all four hotels have the same name?
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#2257592 - 08/03/21 06:47 PM
Re: one conductor depositing into multiple businesses
Barbl
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Diamond Poster
Joined: Sep 2014
Posts: 1,309
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Yes to your first question John, entity F is operating all 4 hotels. No to your second question, they are all different chains ex hilton, hampton, holiday inn, motel 8.
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#2257595 - 08/03/21 06:52 PM
Re: one conductor depositing into multiple businesses
Barbl
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Gold Star
Joined: Feb 2013
Posts: 460
Cape Cod
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OK. If they are all being operated by the same entity, even if they fly different chain flags, they can all deposit to the same account. At some point, though, if FinCEN reactivates its February 2020 CTR ruling, you will have to do a separate Part I for each location, plus one for the entity that summarizes them all.
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#2257597 - 08/03/21 07:00 PM
Re: one conductor depositing into multiple businesses
Barbl
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Gold Star
Joined: Feb 2013
Posts: 460
Cape Cod
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OK. If they are all being operated by the same entity, even if they fly different chain flags, they can all deposit to the same account. At some point, though, if FinCEN reactivates its February 2020 CTR ruling, you will have to do a separate Part I for each location, plus one for the entity that summarizes them all.
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#2257618 - 08/03/21 08:19 PM
Re: one conductor depositing into multiple businesses
Barbl
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Diamond Poster
Joined: Sep 2014
Posts: 1,309
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Thank you John and Randy, as always i appreciate the feedback!
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