The answer to question 23 has not changed. There are two scenarios depicted there, both involving a single joint account owned by John and Jane Smith.
In the first example, John deposits $5,000 cash to the account. Jane separately deposits $7,000 cash to the account the same business day.
In the second example, John deposits $12,000 to the account. Jane makes no deposit to the account.
For the first example, four Part I sections are required because both John and Jane were in different roles for the two deposits. For the $5,000 deposit, John was conductor on his own behalf (2a) and Jane was a person on whose behalf the deposit was conducted (2c). For the $7,000 deposit, Jane was in the (2a) role and John was in the (2c) role. Each Part I would also have item 3 checked.
For the second example, there is only (2a) person (John) and one (2c) person (Jane), so only two Part I sections are completed. Item 3 would not be checked for either.
This was not one of the rules that was suspended in 2020 in response to the pandemic. The suspended rules involved DBAs and entities with multiple locations.
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John S. Burnett
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