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#2260453 - 09/29/21 07:25 PM
CTR - complicated??
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100 Club
Joined: Apr 2005
Posts: 161
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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 “Bâ€, correct? For “Bâ€, 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
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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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
_________________________
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#2260490 - 09/30/21 02:09 PM
Re: CTR - complicated??
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Joined: Apr 2005
Posts: 161
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#2261070 - 10/13/21 08:59 PM
Re: CTR - complicated??
unknown
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100 Club
Joined: Apr 2005
Posts: 161
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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
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Platinum Poster
Joined: Apr 2014
Posts: 677
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Mark does not go on the CTR because Business A did not receive benefit of over 10k.
_________________________
Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney
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#2261072 - 10/13/21 09:01 PM
Re: CTR - complicated??
unknown
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Power Poster
Joined: Nov 2004
Posts: 6,716
Illinois
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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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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria! www.tcaregs.com
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#2263270 - 12/07/21 03:04 PM
Re: CTR - complicated??
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100 Club
Joined: Apr 2005
Posts: 161
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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
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Power Poster
Joined: Nov 2004
Posts: 6,716
Illinois
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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.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria! www.tcaregs.com
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#2276652 - 10/14/22 01:07 PM
Re: CTR - complicated??
unknown
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100 Club
Joined: Apr 2005
Posts: 161
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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
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100 Club
Joined: May 2018
Posts: 236
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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
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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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.
_________________________
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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