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#1997794 - 02/24/15 04:06 PM IOLTA CTR Question
BSA_AML Hoosier Offline
New Poster
Joined: Jun 2012
Posts: 17
Midwest
I'm looking for some guidance on cash transactions involving an IOLTA account.

A lawyer comes into the bank with $20,754.00 in cash. He deposits $10,812.00 in cash to his law firm's account. At the same time, he deposits $9,942.00 into an IOLTA account.

Does the lawyer's client, the owner of the $9,942.00, need to be listed as a beneficiary on the CTR? Or just the law firm for the full $20,754.00 since the deposit benefiting the lawyer's client did not exceed $10,000.00?

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#1997832 - 02/24/15 05:21 PM Re: IOLTA CTR Question BSA_AML Hoosier
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You report both deposits because they are conducted by the same individual (and because they are both conducted on behalf of the law firm).

Because you have to report the IOLTA deposit, you must report the persons on whose behalf it was completed. There are two such persons: the law firm and the law firm's client.
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#1997956 - 02/24/15 08:29 PM Re: IOLTA CTR Question BSA_AML Hoosier
BSA_AML Hoosier Offline
New Poster
Joined: Jun 2012
Posts: 17
Midwest
John - Thanks for you help!

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#2009144 - 04/20/15 10:31 PM Re: IOLTA CTR Question BSA_AML Hoosier
Higgy Offline
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Higgy
Joined: Sep 2013
Posts: 8
Somewhere TN
So... If there are say 4 deposits to different law firms IOLTA accounts but we aggregate by Tax ID# so the total is over 10K for the TN Bar Foundation... do we have to file multiple part 1's? 1 for each of the different law firms making the deposit and 1 for the TN Bar Foundation?

If the deposits individually from the separate law firms are not over 10K then we don't have to file section 1's for whom the deposits were from, correct?

I'm trying to figure this one out and I keep second guessing myself. Thanks.

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#2009159 - 04/21/15 12:28 PM Re: IOLTA CTR Question Higgy
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
While the Bar Foundation receives the interest from the IOLTA accounts, the funds being deposited are not for the benefit of the Bar Foundation.

Under no circumstance would you list the Bar Foundation on the SAR or aggregate transactions conducted by different law firms based on the Bar Foundation's EIN.
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#2009160 - 04/21/15 12:28 PM Re: IOLTA CTR Question BSA_AML Hoosier
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
You would not file a CTR for deposits to IOLTA accounts of different law firms, sinced the TN Bar is not actually the beneficiary of the deposits.

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