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#2257848 - 08/09/21 01:37 PM CTRs for Trust Account with multiple trustees
unknown Offline
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Joined: Apr 2005
Posts: 143
John Smith Revocable Living Trust account
Trustee #1
Trustee #2
Trustee #3

Trustee #1 makes reportable cash deposit into the Living Trust Account (same tax number as Trustee #1).

How to file this CTR?

Part I - Trustee #1 (box a) with Living Trust in field #8?

And additional Part I’s for Trustee #2 and Trustee #3 with box c marked?

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#2257862 - 08/09/21 03:40 PM Re: CTRs for Trust Account with multiple trustees unknown
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,704
Cape Cod
First, unless the trust is operating a business, I would not treat this as an entity deposit.

Because it's a revocable trust, I would treat it as a simple joint account of the three trustees, but I would include the trust name in item 8 in the Part I section for Trustee #1. In all other respects, I would file the CTR as if the account is owned by the three individuals who happen to be the trustees.

Part I for trustee #1, with item 2a checked, all applicable items completed with personal info (other than #8)
Part Is for trustees #2 and #3, with item 2c checked, all applicable items completed with their personal info. No item 8 info

Our friends at FinCEN don't have any good guidance on completing CTRs for revocable trusts in any other way.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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