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#1744533 - 09/26/12 08:28 PM CTR Conductor
Solutions Offline
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Joined: Mar 2012
Posts: 2
A CTR conductor does one transaction (>$10,000) for someone else and then conducts a personal transaction for themself. How do you file the CTR? With the total amount of both transactions? The conductor didn't benefit from the first transaction. I'm so confused!!

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#1744542 - 09/26/12 08:37 PM Re: CTR Conductor Solutions
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You have to aggregate and report cash transactions conducted on behalf of one person or conducted by one individual.

So, you combine the cash amounts into a single CTR. You'll describe one party as a person on whose behalf a transaction was conducted and the other party as a person who conducted a transaction on his own behalf. Include both account numbers.

On a "legacy" CTR (Form 104), you'd have a Section A entry for the conducting party, with "conducted on own behalf" checked in Section B, and a second Section A entry (back of form) with the other party's information (this is the party you described as "someone else").
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John S. Burnett
BankersOnline.com
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#1744547 - 09/26/12 08:45 PM Re: CTR Conductor John Burnett
Solutions Offline
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Joined: Mar 2012
Posts: 2
Thanks so much, John!

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