Hello all!

I'm having a brain cramp and I am struggling with this scenario. John Smith comes in and makes 3 deposits into 3 different accounts:

Account A - his individual checking $7,000.00
Account B - his individual savings $7,000.00
Account C - John and his wife's joint account $500.00

My question is, will the CTR ONLY be in John's name since he is the only one affected by the amount of cash in excess of $10,000, or will his wife also be listed on the CTR as an account owner for the $500.00 deposit? I know this is a CTR 101 question, but like I said, my brain caught a cramp.

Thank you in advance!

Hello,

I would likely not include the wife in that scenario, unless your teller overhead something that would have you believe the wife was somehow involved in the first two deposits.

FinCEN CTR FAQ #23 specifically states that deposits to a joint account are considered to be made on behalf of all parties. The wife would be included in Part I using item 2c for person on whose behalf transactions are conducted and list $500.00 and the joint account number for her.

If a cash-in transaction affecting a joint account is reportable, either because it's reportable by itself (a single cash deposit over $10,000) or because it's one of aggregated cash-in transactions by the same conductor when the aggregated cash-in amount is over $10,000), each owner of the joint account is identified in a Part I entry.

Thank you! That's what I thought, but I'm reviewing someone else's work and I wanted to make sure before I said anything to her. I appreciate your quick response!

Thank you! I did read this, but I wasn't sure about it since the wife only benefited from $500 of the monies. But I got my answer. Thank you!

I'm glad John jumped in on this thread. FinCEN is finalizing changes to how Item 2 is reported on CTRs and he's covering the updates at the BSA Top Gun Conference in March.