Skip to content
BOL Conferences
Thread Options
#1397837 - 05/28/10 06:45 PM CTR - DBA Account Question
bsaLife Offline
Member
Joined: May 2010
Posts: 59
A customer conducted two currency transactions. One transaction was for a personal account and another transaction for his business account. He operates a sole proprietorship that does business under the DBA name XYZ. XYZ has several employees, so the customer and the sole proprietorship have a different TIN. The addresses are also different. What is a proper way to file a CTR on these transactions?
Should I complete two section 'A's? Check the boxes for 1b "multiple persons" and Section B box e "Conducted On Own Behalf"?
Or is just one section 'A' with the customer's SSN and home address and DBA XYZ for #5 with the Section B box e "Conducted On Own Behalf"? Thank you.

Return to Top
BSA/AML/CIP/OFAC Forum
#1397913 - 05/28/10 08:18 PM Re: CTR - DBA Account Question bsaLife
What?? Offline
100 Club
What??
Joined: Feb 2007
Posts: 170
California
Two section A's. One for the Dba using the business address and TIN, and the other with the owners personal information, then if he conducted the transaction, you would mark "conducted on own behalf."

Return to Top
#1397933 - 05/28/10 08:48 PM Re: CTR - DBA Account Question What??
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
While that's not wrong, there really is no need to have separate Section A entries. He and his business are the same "person" and you can file under his name, address and SSN (you can ignore the sole proprietorship's EIN). Just make sure you report both deposits and both account numbers. See FinCEN ruling 2008-R001, at http://www.fincen.gov/statutes_regs/guidance/html/fin-2008-r001.html
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2255458 - 06/17/21 02:46 PM Re: CTR - DBA Account Question bsaLife
CI@MBOC Offline
Junior Member
Joined: Apr 2021
Posts: 42
Don't know if I've ever seen a sole prop DBA and have its own EIN.

What if that sole prop DBA was under the guy's SSN but the account had another signer.....would that other signer also be a part 2(c)?

Return to Top
#2255465 - 06/17/21 03:47 PM Re: CTR - DBA Account Question bsaLife
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,350
Galveston, TX
An EIN for a sole prop is used only for income tax purposes if the sole prop has employees and does not really impact the number used for other reporting purposes. Unless an authorized signer conducted the transaction, they would not appear on a CTR
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2255505 - 06/17/21 06:58 PM Re: CTR - DBA Account Question bsaLife
CI@MBOC Offline
Junior Member
Joined: Apr 2021
Posts: 42
Is it possible to have more than one person "own" the sole prop/DBA? Like, a husband-wife duo?

Return to Top
#2255553 - 06/18/21 03:38 AM Re: CTR - DBA Account Question CI@MBOC
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,712
Illinois
It is possible in some states such as Oklahoma. The answer to your question depends on state law.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2255600 - 06/18/21 04:18 PM Re: CTR - DBA Account Question BrianC
CI@MBOC Offline
Junior Member
Joined: Apr 2021
Posts: 42
Originally Posted by BrianC
It is possible in some states such as Oklahoma. The answer to your question depends on state law.
Curious. How do you record that in bank record? Are they both individually 100% owner? I'm guessing they can't be 50% owner because then wouldn't that be partnership?
I only ask because we have a CTR situation that arose where our DBA grocery market is "owned" by husband/wife per our records, they are both on the FBNS registrant statement. They are both recorded in our system equally as "business owner", so when they make their deposits and go over $10k we've doing a 2(a) and a 2(b) on the husband and wife. This is the first bank I've seen this at with ownerS of a DBA sole prop.

Return to Top
#2255602 - 06/18/21 04:23 PM Re: CTR - DBA Account Question bsaLife
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,350
Galveston, TX
State law and if they need to be treated as a partnership under IRS tax rules are two different things. Not sure what a FBNS statement is.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z