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#2250250 - 03/09/21 04:19 PM CTR Sole Prop
Anonymous
Unregistered

We have a sole prop operating under a DBA with two signers.

I know how to fill the CTR out for the sole prop/DBA per FinCEN's new guidance. However, what I am a little confused about is how to handle the other signer. Our account treats it as if he is a joint owner on the account, so in my mind he should have his own page and it should be indicated that he received benefit of the reportable deposit.

I know there are some system issues with how our sole props are set up, but I am not looking to discuss that at this time. I am just trying to determine if the other signer should be listed as receiving benefit of the deposit as well.

Thank you in advance!

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#2250251 - 03/09/21 04:22 PM Re: CTR Sole Prop Anonymous
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
Well, the first thing you need to do is decide what they are - a co-owner of the DBA or an authorized signer. If they are only an authorized signer - they have no ownership and therefor any transaction would not be conducted on their behalf.
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#2250260 - 03/09/21 06:09 PM Re: CTR Sole Prop Anonymous
praBSA Offline
Gold Star
Joined: Aug 2018
Posts: 348
Agreed with above ^

Determine the business type. A general partnership is a business type where more than one person operates under a single DBA name. You need to determine if this is a general partnership (multiple owners) or a true single person DBA.

As Randy said, if they are just an authorized signer, they wouldn't be included as someone who had a transaction conducted on their behalf.

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