"POA" or "Power of Attorney" refers to the document and the powers it grants to an agent or attorney-in-fact. The person issuing or granting the power of attorney is referred to as the Principal.
As for your question:
No. The attorney-in-fact is the conductor, and will be identified in item 2b as conducting the transaction on another person's behalf. Assuming that the transaction is one done on behalf of the attorney-in-fact's principal (the account owner), the account owner gets their own Part I where item 2c is checked.
Compare your scenario to one in which Joe Smith brings in a reportable deposit to his wife's account. There's no power of attorney involved. Joe is the conductor, and he's identified in a Part I section with item 2b checked. Sally Smith (his wife) is identified in her own Part I with item 2c checked to show that the transaction was conducted on her behalf.
The purpose of the comparison? To show that your conductor's status as attorney-in-fact is irrelevant to how the CTR is completed.
Last edited by John Burnett; 03/02/21 04:47 PM. Reason: typo
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John S. Burnett
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Fighting for Compliance since 1976
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