Can we beat this horse just a bit more?

John, Mary and Tom are all joint owners on a savings account. John comes into the bank alone and deposits $12,000 into the account. We complete a Part 1 Section A for all 3 account owners since they all benefited. But I'm confused about Part 1, Section B.

For John's Part 1, section B we would check "Conducted on own behalf. That's easy because he was the conductor.

What do we do with the multiple persons (page 2 of Form 104) Mary and Tom's Part 1, section B? It is requesting individual(s) conducting transaction(s) if other than above. Do we repeat John's information (since he was the only transactor) for both Mary and Tom's Part 1 Section B.... or do we just leave it blank?

Thanks in advance for any help.

Help!- training starts tomorrow at 7:45 a.m. If those CTR instructions were just a tad bit more extensive there wouldn't be so dang many questions.

You only have to provide Section B information on John and you do that by listing him on the front in Section A and checking "on own behalf" in Section B. You leave the two other section B portions of the form (on the reverse) blank. That tells FinCEN and the IRS that only John was there with the cash.

Thanks again John.

It doesn't make much sense, because there's no "on own behalf" check-box for the back of the form. But you leave Section B blank, based on the "if other than above" instruction.

Keep in mind a general rule - a person should only be identified on a CTR one time, therefore, if they are the beneficiary, then there is no need to list them again as the transactor. "If other than above" is your key to not having to list Mary a second time. Also consider that Mary was with John, but John did the transaction.

Fincen would be more concerned that Frank, James, Juan and Lefty were making deposits to the account in a structuring manner.