We have a customer that operates multiple businesses, all DBAs under one larger corporation. They are an MSB, so they deposit cash to many of their DBA accounts multiple times per week, requiring very frequent CTRs. There have been up to 20 separate DBAs on one CTR, so in the past, we have used separate part 1s for each as each DBA has a different business type and NAICS code. Our system recently had an update, which changed how the DBAs are reporting. Basically, it's more in line with the CTR FAQs concerning this issue.

I'm curious how others have handled this situation. There isn't enough room on the alternate name line to list each DBA separated by a semicolon, and there can be only one NAICS code per part 1. Has anyone been involved in a similar situation, and if so, what did you do? I've submitted a question to FinCEN, but I haven't heard back yet. If it were two or three DBAs, I wouldn't be that concerned, but the current one I'm working on has 15 DBAs that should be listed. The business types are check cashing, pawn, jewelry store, cell phone store, cell phone repair shop, etc. The business types are different enough that there isn't a NAICS code I could use to cover them all.

Maybe I'm overthinking this?

I finally heard back from FinCEN for this question. This was their response:

"You should only list a single DBA name in the "Alternate name" field. If the transactions are not clearly on behalf of one
of the specific DBAs, you may complete separate Part Is with the DBA of each being listed in the respective "Alternate
Name" field."

So this is exactly how we were filing these. I know from research that others were instructed to list each DBA separated by a semicolon or comma, but this is not what I was told. I'm a little irritated I didn't get the same instruction because if our system can't go back to how we were reporting before its update last weekend, it's just going to create a lot more work on our side. Frustrating...