We have a commercial account (donut shop) that at times will have 10 employees bringing in cash deposits. All deposits are physically brought into the bank, the night depository is not used.
Is it necessary to list all 10 people on the CTR under section B, or is there a way to go around this? I've been told by others that it is allowable to only list the one person who brought the cash in that meets the $10,000 threshold. If this is so, can anyone direct to where I can find that in writing?
Thanks.

If they are bringing in less than $10M but combined it is over $10M then check off Multiple Transactions - and don't list anyone.

But where does it say we could do that?

In Section B.

Multiple Transactions is a reason to leave Section B blank.

"If Section B is left blank or incomplete, check the box(es) below to indicate the reason(s)."

Go to http://www.irs.gov and print out a paper CTR with all the instruction pages.
It provides alot of information for you on CTRs and CTR filing.

If you have knowledge of the individuals conducting the transactions, you should identify them in the CTR. The multiple transaction option exists for those instances where the Bank does not have the knowledge.

I think you need to look at your own procedures first. If you identify transactors at a certain dollar threshold, then you need to report any transactor that you identify. Also, the person that actually goes over the $10,000 and any individual after that should be identified.

Our regulators have always required that we attempt to identify all transactors, even if it means contacting the customer after the fact. I would be real careful about just checking the multiple transaction box and ignoring the need to identify the transactor(s). Your internal procedures will dictate when to identify/list the transactor.

I believe that maintaining the names and ID's of an endless number of Donut Shop employees (non-customers) is not of interest to the IRS.
The purpose of the Multiple Transactions box is for situations like this.

I appreciate your response, but you're getting away from my original query.
"I've been told by others that it is allowable to only list the one person who brought the cash in that meets the $10,000 threshold. If this is so, can anyone direct to where I can find that in writing?"

I have never seen that in writing. Instructions require that you identify all transactors whenever possible.

You simply won't find that in writing anywhere official, because it runs counter to what FinCEN (and the IRS before it) has said in the past. The fact of the matter is that there has been guidance that says you should try to determine who made the multiple deposits. The "excuse" box is there for you to use when you are unable to obtain all the of the information on all of the transactors.

What you may have heard is a suggestion that you might get away with checking the box and not following up to identify the individuals in Section B. And that's correct. You may get away with it. But it's not official advice, and you could get burned in an exam if it's apparent that you're making no effort to file a complete CTR.

Yea, I didn't think so either. However, I've had a representative from FINcen and an audit firm tell me this is allowable.

If you identify all the individuals in Section B, does Section A need to be filled out 10 times also, repeating the Donut Shop information?

No - one section A per beneficiary.

That is what I thought but we just got 2 returned with the reason being Section A not filled out. I haven't actually seen the return yet, just got a call from the branch. Maybe there is more to it.

I have just dealt with a similar situation. One person brought in over $10,000 in cash that went into several business accounts. A second person made some cash deposits into the same accounts but under the $10,000 amount. In addition there were transactions that were serviced by an armored car. All this happened over the weekend. After checking with the company we use that audits us AND the FEDERAL examiner that happened to be here at the time doing a BSA exam, I ended up with a 4 page CTR so that I listed all the accounts involved and all the people involved. I did not let either party know my thoughts first, which was to list every account and every person, armored car included. I got the same response from both parties.

This instance is one business that had 2 conductors. I think someone new must have been at the helm that day.