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#107527 - 08/18/03 07:59 PM CTR filing - joint owner
Anonymous
Unregistered

A customer walked in and deposited $14,000 cash. His wife (who was not with him) is a joint owner on the account. Do we include her on Form 4789 under the guise of "multiple persons" (question 1), even though she wasn't present when the deposit was made?

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General Discussion
#107528 - 08/18/03 08:01 PM Re: CTR filing - joint owner
P*Q Offline

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P*Q
Joined: May 2001
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Somewhere
Yup.

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#107529 - 08/18/03 08:10 PM Re: CTR filing - joint owner
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
If it is a joint account, all owners of the account benefit from the deposit. Therefore, list all owners as beneficiaries. If it is a withdrawal, not all owners may benefit. Therefore, list only those present.
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David Dickinson
http://www.bankerscompliance.com

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#107530 - 08/19/03 06:33 PM Re: CTR filing - joint owner
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
List the owner making the deposit on the face of the 4789, in Section A Part I. In that way, you can check the box for "conducted on own behalf" at the start of Section B, and omit the rest of Section B.

List the other joint owner(s) in Section A entries on the reverse of the form. Check "multiple persons" in item 1 on the front.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#107531 - 08/20/03 12:26 PM Re: CTR filing - joint owner
JimK Offline
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Joined: Oct 2002
Posts: 107
Alexandria, VA
A similair issue occurred yesterday. Husband and wife, both joint owners of the account independently deposited amounts that totalled over $10k. After reading the form instructions, which don't mention joint owners, we also concluded it was reportable and listed both names.
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Jim K

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#107532 - 08/20/03 04:07 PM Re: CTR filing - joint owner
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You are correct in noting that the instructions with Form 4789 do not discuss joint owners. The reference is oblique, in that we are required to list all persons "on whose behalf" the deposit is made. I think it's a pretty easy segué to assume that, if I deposit $15,000 cash to the joint account I hold with my wife, she benefits.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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