On a CTR, can a DBA conduct a transaction on its own behalf?
John Dobbs DBA Johnny's Pizza, TIN 72-xxxxxx, DOB blank since it is an entity, John Dobbs did the transaction so we checked "conducted on own behalf" and left Part B blank. Is this correct, or should we have indicated John Dobbs in Part B, and included his personal social security number in Part B?

And individual doing business using a trade name is not an entity separate from the individual, regardless their use of a TIN or not. A trade name is a FICTISIOUS name.

I would have put John Dobbs in section b. His identfying information is different from the DBA. He actually did the transaction for the business, not for his personal account.

Actually, our friends at FinCEN would have you complete the CTR a different way. In FIN 2006-R003, we're instructed to list the individual (with his/her SSN, DOB, and residence address) in Section A on the front, check "conducted on own behalf" above Section B (leave Section B blank), and complete a second Section A entry on the business, by listing the owner again, adding the DBA name in item 5, supply the business address and the EIN (if one has been assigned) for the business. Back on the front of the form, be sure the "multiple persons" box is checked in item #1.

It is FinCEN's view that the transaction benefits both the owner as an individual and the business, so both are listed. It's the only example I know of where you would list the same individual more than once on a CTR. It's also a bit of tortuous reasoning that arrived at the FinCEN ruling, IMO.

Thank you - this was very helpful.