For those of you familiar with FinCEN ruling 2006-R003 just a quick question...

For sole proprietorships that have the same TIN as the owner on the account (for example, DBAs) are you still identifying the business in part I, section A on the CTR and in an additional part I, section A on the individual?

We have been seperating them per the guidance but it seems redundant if the ONLY thing different in the first section A is the DBA name.

??

We have been filing the CTRs following the guidance, by putting the owner in Part 1 Section A and then the DBA name of the business on page 2, Part 1 Section A. We also check Multiple Persons. It seems silly, but from previous threads it was clear that the guidance requires it to be done this way.

This is what we do: Check multiple persons on line 1, complete the info on the individual on the 1st Section A, check block "e" on page 1 Section B, go to 2nd Section A complete the exact same info-(assuming that it is the same) and add the d/b/a on line 5.

Maye if the BOL BSA gods are nice, particularly the Almighty Ken, he might just put the excerpt from his Q & A's (#45) from his August BSA webinar here. As usual, he did a thorough job of answering this question by submitting examples to FinCEN and asking for a written response. It is a reference tool I use often!

We're glad that you found the webinar useful. Ken may want to paraphrase part of his Q&A or copy and paste that item here. What we'd rather do is encourage users to buy any of the excellent BSA programs Ken has done from the Banker Store, http://www.bankersonline.com/store/ as there is always a lot of excellent content in each of his programs.