I have not seen this example yet. In fact the FAQ does not list it, and it's the most common transaction.

George and Martha are JO's on a checking account. George makes the CTR deposit, just one, for $10,100 cash.

How many Part I's do we file on George? The way I read the updated 2020 FAQ, the answer is two - One box 2a and one with box 2b checked. Martha is not there.

Martha needs to be on the CTR as person on whose behalf transaction was conducted as she is benefiting from the deposit.

Thanks, but that's not the question. I know Martha will get 2c checked.

Original Anon:
I know that FAQ #16 changed. But the way that FAQ is titled, leads me to think my situation applies. I acknowledge that the examples used in FAQ 16 are not my situation. And I see that the Note in FAQ #23 is my situation. So, what to do? Does FAQ #16 only apply to situations where there's more than one account involved and the conductor is there for multiple roles (a different for each account)? Then that's what the FAQ oughta say!!

If George is on the account, he is conducting on his own behalf. He would not need two pages. If he made a deposit to his account and an account that Martha owned without him, he would need two pages.

I think the response of adding Martha was only trying to be helpful as there was no mention of putting her on the CTR.

Orig Anon,
Thanks everyone. I think I answered my own question, I just remember all this hubub about roles rules changes in 2020 that made me think my situation described, now had new rules. But I see FAQ 23 has not changed. It would be nice if FINcen would simply qualify that there has to be two transactions to two different account for it to apply. Seeing FAQ #23 gives me reassurance that only one part 1 for the conductor is necessary.

Please check the date of the Q&A that you are using. I attended a training of Deb Crawford in 2020 and she gave an exact example of what you are describing and in her example- the CTR filed had 3 Part 1s: Martha with 2c and George with 2a and George with 2b

The FinCEN's FAQs as of today still list the same answer that Anon found, which states that only two part Is are necessary. There is no need for a 2b for George.

https://www.fincen.gov/frequently-asked-questions-regarding-fincen-currency-transaction-report-ctr

I'd check Deb's example again. You likely will find that George made a deposit to Deb's individual account which would necessitate a part 2b for George.

Thanks for suggestion BUT I have checked the example many times - - the example is: Husband comes into deposit $11,000 cash into his JOINT account with his wife. This scenario then provided a Part 1 for wife 2c and Part 1 for Husband 2a and Part 1 for husband 2b. So unless something changed, this example is very clear.

CHANGE of OPINON - all I appreciate my peers and I just couldn't let this sit so - - I emailed Deb Crawford @ Gettechnical Inc. I attached her training materials that I had attended and referenced the specific example and questioned it due to the conversation in this chat. Ms. Crawford responded to me late last night and I could hardly wait to reply to you all. The specific example indeed was retracted or opinion CHANGED. This example just needs 2 part 1s - - one for husband 2a and one for wife 2c. I apologized for my misdirection and hope to not have caused any harm. She provides several examples on her website if you want to check them out.

Original Anon here: I see the follow-on discussion, and as you can surmise, this issue can be confusing! I appreciate the discussion. Good job Go_Huskers! You followed through. And for the record, I'm a Husker fan since 1970. Go Big Red.

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.