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#2247444 - 01/11/21 03:42 PM CTR Help Needed
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Joined: Aug 2013
Posts: 149
I have to file a CTR that is more complicated than most that we have and need some help. This is the situation:
Person A deposits $13,000 cash in her checking account. She is the sole owner. Person A deposits $1,600 cash in an account owned by business B (an LLC). Person A deposits $20 cash in her checking that is owned jointly with person C.
Person D deposits $200 cash in a checking account owned by Person A and Person E. Person D also deposits $144.00 cash in a checking account that he owns solely.
I’m trying to decide how Part One will be completed. This is what I have come up with.
Person A will have a Part One with 2a marked for a total of $14,820. Business B will have a Part One with 2c marked for $1,600. Person C will have a Part One with 2c marked for $20. Person E will have a Part One with 2c marked for $200. Person D will have a Part One with 2b marked for $200.
Is this all or do I have to include the $144 Person D put in his own account? And is there anything else I have missed? Any help is greatly appreciated.

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#2247452 - 01/11/21 04:20 PM Re: CTR Help Needed Complycated
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,074
Illinois
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. wink
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#2247455 - 01/11/21 04:31 PM Re: CTR Help Needed BrianC
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Should the Part I - Person A with 2b be $1,620 since A deposited $1,600 to Business B and $20 to a joint account of A and person C?

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#2247458 - 01/11/21 04:49 PM Re: CTR Help Needed Complycated
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,074
Illinois
Since Person A was a joint owner on the account with person C, that $20 is accounted for in the 2a bucket for person A.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
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#2247460 - 01/11/21 05:03 PM Re: CTR Help Needed Complycated
Complycated Offline
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Joined: Aug 2013
Posts: 149
Thanks for the help Brian!

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#2247490 - 01/11/21 09:04 PM Re: CTR Help Needed Complycated
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,408
Cape Cod
One related issue: The three Part I sections for Person A will have the Multiple Transactions item (#3) checked to indicate Person A had more than one transaction by them and/or on their behalf.

Person D made two transactions, but one of them (for $144) is dropped and ignored. Persons B, C, D and E are only included on the CTR because they either conducted one of the transaction made on behalf of Person A (D) or Person A made a transaction on their behalf (B, C, E).

When a transaction is conducted on the transactor's own behalf (2a checked), the cash amount for that transaction is also counted as conducted on the transactor's behalf when determining whether aggregated transactions exceed $10,000 to trigger a CTR.
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BankersOnline.com
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#2247503 - 01/12/21 02:54 PM Re: CTR Help Needed John Burnett
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Joined: Aug 2013
Posts: 149
Thanks John!

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