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#2079870 - 05/23/16 05:57 PM CTR on Cashed Check with Multiple Payees
BSA1989 Offline
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Joined: Nov 2015
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We have an insurance check payable to three individuals: Jane Doe & John Doe & Ken Jones. John Doe was the only individual present when cashing the check. On our CTR, do we list all three as benefactors (Jane Doe & Ken Jones on whose behalf the transaction was conducted) and John Doe as the transactor? Or do we only include John Doe as conducting the transactions on his own behalf (benefactor & transactor)?

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#2079889 - 05/23/16 06:19 PM Re: CTR on Cashed Check with Multiple Payees BSA1989
John Burnett Offline
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John Burnett
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Welcome to BankersOnline's discussion forums.

If you have information such that you believe the check was being cashed by John Doe on behalf of the other two payees and himself, your CTR should reflect that belief, and you'd have three Part I entries:

The first, on John Doe, as a person conducting the transaction on his own behalf (2a)
The second and third, on Jane Doe and on Ken Jones, each as a person on whose behalf the transaction was conducted (2c).

If you don't have such information, you could legitimately assume that John Doe was acting only on his own behalf. If the payees were listed in the alternative (neither the word "AND" nor an ampersand (&) was used in listing the payees), you'd have a stronger argument that John Doe could have been acting strictly on his own behalf.

If the check was not payable in the alternative (the payee read like "Jane Doe, John Doe & Ken Jones" as you have suggested in your question), many of not most banks would require that all three payees indorse the check in the presence of the teller, and provide their IDs. Usually, the only time most banks would cash such check when only their customer is present would be a situation in which their customer is reliable, well established as a customer, and able to pay for the check if their is a claim later that one of the other payees' indorsements was forged.

Just for the record, a "benefactor" is a person who provides some good or benefit for another. The Bill & Amanda Gates Foundation, for example, is a benefactor for many charitable organizations. The person receiving the benefit is often called the "beneficiary." But CTRs don't involve benefactors and beneficiaries. They do involve conductors and "persons on whose behalf" a transaction is conducted.
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