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#2260453 - 09/29/21 07:25 PM CTR - complicated??
unknown Offline
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Joined: Apr 2005
Posts: 159
Here’s the scenario:

A deposits $500 into account owned by A, B, C

E deposits $7000 into account owned by E, B, C

B deposits $6000 into account owned by B and F.

So, B is the account owner for all three accounts.


Two Part 1 sections for “B”, correct?
For “B”, we would put $6000 (Conductor on own behalf) and also $7500 (account owner on behalf of)?
And list the other owners accordingly?

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#2260464 - 09/29/21 09:01 PM Re: CTR - complicated?? unknown
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
The trigger for the CTR is the fact that there was $13,500 deposited on behalf of B

All three deposits are included, so yes, you have

Part I for B, with 2a and 3 checked, for $6,000
Part I for B, with 2c and 3 checked, for $7,500
Part I for A, with 2c checked, for $500
Part I for C, with 2c and 3 checked, for $7,500
Part I for E, with 2a checked, for $7,000
Part I for F, with 2c checked, for $6,000
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#2260490 - 09/30/21 02:09 PM Re: CTR - complicated?? unknown
unknown Offline
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Joined: Apr 2005
Posts: 159
Thank you

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#2261070 - 10/13/21 08:59 PM Re: CTR - complicated?? unknown
unknown Offline
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Joined: Apr 2005
Posts: 159
Here’s this scenario:

John deposits $6000 cash into Business A and $7000 cash into Business B. Businesses are not comingling funds.

Mark deposits $200 cash into Business A.

Part I for Business A with 2c - $6000
Part I for Business B with 2c - $7000
Part I for John with 2b, multiple - $13000

Does Mark go on this CTR even though Business A did not go over $10000?

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#2261071 - 10/13/21 09:01 PM Re: CTR - complicated?? unknown
Sunshine Lady Offline
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Sunshine Lady
Joined: Apr 2014
Posts: 673
Mark does not go on the CTR because Business A did not receive benefit of over 10k.
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#2261072 - 10/13/21 09:01 PM Re: CTR - complicated?? unknown
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
Correct.

Mark's deposit is not aggregated because Mark did not conduct over $10,000 and business A did not have over $10,000 deposited on its behalf.

Our CTR aggregates John's two deposits because John conducted over $10,000.
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#2263270 - 12/07/21 03:04 PM Re: CTR - complicated?? unknown
unknown Offline
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Joined: Apr 2005
Posts: 159
Hi John,

Going back to the initial scenario - if A also made a deposit of $1000 cash into his sole account, would this deposit need to be reported for A as additional 2a? Or is this deposit not reported since the CTR triggered based on B?

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#2263277 - 12/07/21 05:16 PM Re: CTR - complicated?? unknown
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,685
Illinois
A did not deposit more than $10,000 and A did not have more than $10,000 deposited on their behalf so that would not be aggregated.
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
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#2276652 - 10/14/22 01:07 PM Re: CTR - complicated?? unknown
unknown Offline
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Joined: Apr 2005
Posts: 159
John deposits $15,000 cash into LLC business account

Mary deposits $300 cash into John’s personal account

Does $300 need to be reported for John on this CTR?

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#2276671 - 10/14/22 04:15 PM Re: CTR - complicated?? unknown
SmallBankBSA Offline
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Joined: May 2018
Posts: 232
No, you would only report on John depositing the $15000 into the LLC business account.

You would report on that $300 deposit if John were the conductor.

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#2276765 - 10/18/22 08:20 PM Re: CTR - complicated?? unknown
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Question 1: Did any person involved in the transactions in question complete transactions totaling more than $10,000 in cash?

If yes, you file a CTR showing that conductor and all parties on whose behalf that conductor conducted the transactions.

Question 2: Was there any person involved in the transactions a person on whose behalf transactions more than $10,000 were conducted?

If yes, you also include the transactions made on behalf of those persons, including their conductors.
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BankersOnline.com
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