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#2259721 - 09/15/21 02:13 PM CTR Help
compgal21 Offline
Junior Member
Joined: Jan 2021
Posts: 45
Ok - here is the scenario.

Customer A makes a deposit on the behalf of Customer B and Customer C.

Customer B is a business - the amount deposited is $8,100
Customer C (her daughter) - the amount deposited is $2,000.

I know Customer A will be included on the CTR as conductor on own behalf. However, do I need to list the benefactors considering the deposit into each account did not exceed $10,000.01?

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#2259737 - 09/15/21 03:14 PM Re: CTR Help compgal21
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,721
Illinois
Welcome to BOL with one of your first posts. Before I answer, first, a little social media fun. The use of the word 'benefactor" as it relates to a CTR is the BOL equivlent of "*you're" that you may see on Twitter.

Benefactor is defined as a "person who gives money to help a cause" In other words a benefactor is someone who gives a donation.

CTRs have "persons who conduct transactions" and "persons on whose behalf transactions are conducted" In your example, since Customer A conducted transactions that exceed $10,000, aggregation rules require that we also include the persons on whose behalf those transactions were conducted.

You mentioned including Customer A as "Conductor on own behalf." Is Customer B a sole-propreitorship, corporation, LLC, partnership?

Is customer A a joint owner on Customer C's account.

The answers to these questions will determine whether Customer A is conducting on own behalf or conducting on behalf of another.
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#2259739 - 09/15/21 04:20 PM Re: CTR Help compgal21
compgal21 Offline
Junior Member
Joined: Jan 2021
Posts: 45
The customer is not a joint on either of the accounts - as a mistake I put "conducting on own behalf" on the post when I should have put "conducting the behalf of another".. So, if i am correct on the CTR -

Customer A conducts two transactions on behalf of Customer B and Customer C. Therefore, Customer B and Customer C needs to be listed on the CTR

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#2259741 - 09/15/21 04:31 PM Re: CTR Help compgal21
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,721
Illinois
Correct.

Customer A - 2b $10,100.00 plus Item3 Multiple Transactions
Customer B - 2c $8,100
Customer C - 2c $2,000
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

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