Skip to content
BOL Conferences
Thread Options
#722815 - 04/26/07 09:49 PM CTR question
OVERWHELMED Offline
Member
Joined: Sep 2006
Posts: 92
the south
A lady deposits 10,000 cash into her checking account. No CTR necessary for this transaction. BUT she next deposits 9000.00 cash into her son's checking account. Ok, if I understand correctly, CTR is definitely now necessary. So I list the lady in Section 1A and her son in another Section 1A with nothing in Section B? Or does she go in Section B as doing it on behalf of the son? The son never actually came into the bank but would definitely benefit from the funds being deposited into his account.

Return to Top
BSA/AML/CIP/OFAC Forum
#722817 - 04/26/07 09:55 PM Re: CTR question OVERWHELMED
Tiger Fan Offline
100 Club
Joined: Jun 2002
Posts: 180
As you stated, both would be listed in Section A. You would mark box e - "Conducted on own behalf" in Section 2. I would also check to see if there may be structuring going on if the deposits were made at different times.

Return to Top
#723325 - 04/27/07 05:22 PM Re: CTR question Tiger Fan
OVERWHELMED Offline
Member
Joined: Sep 2006
Posts: 92
the south
So marking "Conducted on own behalf" wont insinuate that the son was present also?? He did not conduct any of the transaction.

Return to Top
#723326 - 04/27/07 05:23 PM Re: CTR question Tiger Fan
OVERWHELMED Offline
Member
Joined: Sep 2006
Posts: 92
the south
So marking "Conducted on own behalf" wont insinuate that the son was present also?? He did not conduct any of the transaction. I will keep on check on the accounts but do not at this time suspect structuring because both transactions were made at the same time. It has never occurred on the accounts in the past.

Return to Top
#723335 - 04/27/07 05:31 PM Re: CTR question OVERWHELMED
GMetz Offline
Member
Joined: May 2006
Posts: 60
Kentucky
You can list the lady in the first Section A and in Section B check "Conducted On Own Behalf" then in the other Section A you will list her son and below him you will have to enter the lady's info again because she conducted the transaction on his behalf. You would only leave the second Section B incomplete if her son was with her. Make sense?

By marking "Conducted On Own Behalf" on the first page, you are ONLY referencing the first page. That's why the Section B on the 2nd page says "Individual(s) Conducting Transaction(s) (if other than above)

Return to Top
#723343 - 04/27/07 05:35 PM Re: CTR question OVERWHELMED
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
No-if the son were present there would no need for a CTR. By checking multiple persons they will know that one individual conducted transactions on behalf of 2 or more individuals. You identified that individual on page 1. I hope I didn't confuse things.

Return to Top
#723411 - 04/27/07 06:18 PM Re: CTR question nemsi
OVERWHELMED Offline
Member
Joined: Sep 2006
Posts: 92
the south
Thanks to all of you! I get it now. I know this isnt difficult but sometimes I get to thinking too much and make harder than it is.

Return to Top
#723444 - 04/27/07 06:44 PM Re: CTR question GMetz
JubileeAnne97 Offline
100 Club
Joined: Mar 2007
Posts: 118
Empire State
GMetz and Overwhelmed, please read CTR with multiple Persons Benefiting
_________________________
An ounce of prevention is worth a pound of cure.

Return to Top
#723449 - 04/27/07 06:48 PM Re: CTR question OVERWHELMED
OVERWHELMED Offline
Member
Joined: Sep 2006
Posts: 92
the south
Well, I thought I had it. As I started filling it all in, I came up with more questions..Sorry!! Ok, because the lady did the transaction and the teller took her ID information, that part is fine. On the CTR, however, it asks for method used to verify the person on whose behalf it was done. Because the son was not present, his identity was not verified. He has an account here, but it is old and opened before there were specific CIP requirements. We do not have his DL number on record. I'm guessing we're going to have to contact him for that info in order to finish filling this out, right? What happens if we are unable to get in touch with him?

Return to Top
#723462 - 04/27/07 07:01 PM Re: CTR question OVERWHELMED
JubileeAnne97 Offline
100 Club
Joined: Mar 2007
Posts: 118
Empire State
Under the Section 326, you don't have to reverify his identity, however, his accout is subject to file a CTR as a beneficiary account, which means you have to contact and get his ID information and fill out the second section A. You cannot leave out the blank. If you are unable to contact him, you may ask his mother who made a currency transaction.
_________________________
An ounce of prevention is worth a pound of cure.

Return to Top
#723514 - 04/27/07 07:35 PM Re: CTR question JubileeAnne97
Parrot Crazy Offline
New Poster
Joined: Jul 2006
Posts: 6
Oklahoma
I have a question. Is mom joint on son's account also? Or is it just the son?

Return to Top
#723650 - 04/27/07 08:50 PM Re: CTR question JubileeAnne97
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
Do you have his name, street address, date of birth and social?

Return to Top
#723652 - 04/27/07 08:50 PM Re: CTR question Parrot Crazy
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
If the person benefiting from the transaction is not present, you need not provide ID information on that person. See the CTR instructions for item 14.

In this scenario, check multiple persons in item 1, put Mom's info in Section A (front), check "conducted on own behalf" in Section B, flip the form over and complete Section A for the son. Do not enter the mother's info in a second Section B entry.

The fact that you do not check any other "excuse box" in Section B on the front of the form tells the IRS there is only one individual who completed all reported transactions.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#723695 - 04/27/07 09:38 PM Re: CTR question JubileeAnne97
OVERWHELMED Offline
Member
Joined: Sep 2006
Posts: 92
the south
Thanks for the input John. I had actually just found the Box 14 option. I had always thought of "other" as other ID rather than "Other" as in N/A. It's amazing what you find when you quit rushing around and take time to read every detail, huh?
The mother is not on the son's account. I do have his soc sec#, address,and occupation, but I DONT have his birthdate. I am going to try to contact him for that.

Return to Top
#724171 - 04/30/07 06:25 PM Re: CTR question OVERWHELMED
McGruff Offline
Gold Star
McGruff
Joined: Feb 2004
Posts: 262
Texas
Our new accounts people put signer's DOB and DL on the signature cards. This has saved me a ton of time in filling out CTRs. Also, I have some very good tellers who know to get as much information as possible at the time of the transaction. Sometimes they give me more info than I need, but that's OK with me......
Last edited by McGruff; 04/30/07 06:26 PM.
Return to Top
#724367 - 04/30/07 08:13 PM Re: CTR question McGruff
OVERWHELMED Offline
Member
Joined: Sep 2006
Posts: 92
the south
For several years now, our signature cards include all of the information needed on CTRs even including occupation. This being an old account tho, that was not the case. Makes you appreciate that little bit of extra work and shows it's definitely worth the effort eventually.

Return to Top

Moderator:  Andy_Z