The best way to determine what needs to be aggregated and what doesn't is to remember that your CTR is based on the dollar amount deposited by or on behalf of the same person.
Person A By: $14,620 Person A on behalf of: $13,220
Business B By: $0 Business B: on behalf of: $1,600
Person C: By $0 Person C on behalf of: $20
Person D: By $344 Person D on behalf of: $144
Person E By: $0 Person E on behalf of: $200
For aggregation purposes, which dollar amount is in excess of $10,000. Since person A had both by and on behalf of exceeding $10,000, we must aggregate all transactions that person A conducted or benefited from and identify all the persons involved and their roles. Also remember the new CTR rules that went into effect 9/1/20 that require multiple Part I's for the same person if more than one rule in item 2 applies to them.
Part I - Person A - $13,020 marked with 2a (Deposits made into accounts person A owns)
Part I - Person A - $1,600 marked with 2b (Deposit made on behalf of Business B)
Part I - Person A - $200 marked with 2c (Deposit made by person D on Person A's behalf)
Part I - Business B - $1,600 marked with 2c (Deposit made on behalf of the business)
Part I - Person C - $20 marked with 2c (deposit Person A made into joint account)
Part I - Person D - $200 marked with 2b (Deposit made on behalf of person A. The $144 deposit is excluded since person D did not deposit more than $10,000 or have more than $10,000 on their behalf)
Part I - Person E - $200 marked with 2c (Although person E did not have more than $10,000 deposited on their behalf, since they were joint with person A they end up being included)
Part II of the CTR will total $14,820 since we exclude the $144.
Someone please check my work.
