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#2251084 - 03/23/21 11:19 PM I just forgot how to do a CTR!?!
Anonymous
Unregistered

I feel like I am taking crazy pills.

Person A makes a payment on joint credit card with Person B for $11k. CTR required, both people benefit.

However, same day, Person A makes a $5k deposit into an account that she shares with Person C and Person D.

So the CTR should show Person A as conducting on own behalf for $16k; Person B receives benefit of $11k; Person C receives benefit of $5k; and Person D receives benefit of $5k. Correct?

I thought the CTR FAQs addressed this directly, but I am only finding out how to handle it when joint owners both receive over $10k in benefit and different conductor scenarios.

I have been doing this for many years-- but today my mind has totally blanked. Help!

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#2251131 - 03/24/21 05:15 PM Re: I just forgot how to do a CTR!?! Anonymous
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 5,886
Illinois
You always aggregate deposits made by or on behalf of the same person.

In this instance we have $16K brought in by the same person so we must include all individuals on whose behalf those transactions were conducted which means four Part I's as you have illustrated.

Person A - Box 2a
Persons B-D all Box 2c

You have the amount breakdowns correctly. Lastly you only check "multiple transactions" for Person A since none of the other individuals in Part I were part of more than one transaction.
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#2251167 - 03/24/21 07:41 PM Re: I just forgot how to do a CTR!?! Anonymous
GrannieTwo Offline
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Joined: Nov 2010
Posts: 180
Central IL
If Person B, C & D were the primary persons on the account, and A was making the deposit, I agree with Brian, but in the scenario Person A , alone made those deposits. If B, C and D aren't with Person A, how is it to there benefit? Do they even know about the deposit? What if Person A is making the deposit to buy a car for themselves. How did B benefit? Boy, if I'm wrong and I'm sure you are going to tell me I am, I have misunderstood this. Oh my. 😕
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For when I am weak, then I am strong. 2Cor 12:10

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#2251169 - 03/24/21 08:03 PM Re: I just forgot how to do a CTR!?! GrannieTwo
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,522
Originally Posted by GrannieTwo
How did B benefit?

B benefits by being a joint owner. See CTR FAQ 23:

How do I properly complete Part I on the FinCEN CTR for deposits into a joint account? What amounts do we show in Item 21 for each Part I? For example, John and Jane Smith have a joint account together. John Smith deposited $5,000 into the account; later in the same business day, Jane Smith deposited $7,000 into the account.

When a deposit is made into a joint account, the deposit is presumed to be made on the behalf of all account holders because all account holders have potential access to the account balance, and multiple Part Is are required. In this example, the financial institution would complete four Part Is, two for John Smith and two for Jane Smith since each person has more than one Item 2 role.

One of the Part Is for John Smith would be completed by checking 2a "Person conducting transaction on own behalf" and entering $5,000 into Item 21 and the account number of the joint account. The other Part I for John Smith would be completed by checking 2c "Person on whose behalf transaction was conducted" and entering $7,000 into Item 21 and the account number of the joint account. One of the Part Is for Jane Smith would be completed by checking 2a "Person conducting transaction on own behalf" and entering $7,000 into Item 21 and the account number of the joint account. The other Part I for Jane would be completed by checking 2c "Person on whose behalf transaction was conducted" and entering $5,000 into Item 21 and the account number of the joint account.

Note: If Jane Smith did not conduct a deposit, but John Smith deposited $12,000 into the joint account, there would only be two Part Is. One Part I would be for John Smith as 2a "Person conducting transaction on own behalf" and entering $12,000 in Item 21 and the account number affected. The other Part I would be for Jane smith, checking 2c "Person on whose behalf transaction was conducted," entering $12,000 in Item 21, and providing the account number affected.
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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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#2251170 - 03/24/21 08:04 PM Re: I just forgot how to do a CTR!?! Anonymous
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 76,109
Galveston, TX
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2251414 - 03/29/21 07:25 PM Re: I just forgot how to do a CTR!?! Anonymous
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,089
Cape Cod
When the funds are deposited to the joint account, each joint owner has an equal claim to the balance, whether or not he or she knows about the deposit.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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