CTR for entity with multiple accounts

With the rule effective Sept 1 to report multiple Part 1 pages, if one conductor makes deposits into multiple accounts of the same entity totaling more than $10k,can only one Part 1 page with the total cash in amount and all account numbers be complete for the entity? Or does a Part 1 page for each separate account and deposit amount need completed?

The rule that was effective on September 1st says that multiple Part I's are required if multiple "roles" in item 2 apply.

So if I make a deposit to my personal account (conducted on my own behalf) and I make a deposit to my business account (conducted on behalf of another) then I would have two part I's (2a and 2b).

In your scenario, the business had all of the deposited to its various accounts conducted on its behalf (item 2c) so there would only be one part I for the business with all applicable amounts and account numbers listed. Similarly there would only be one part I for the person making the deposits on behalf of another (Item 2b).

That was my hope, and my intention of filing. Thank you

FinCEN suspended its FIN-2020-R001 ruling and its changes to the filing requirements for sole proprietorships and legal entities.

But I don't think your question is affected by that ruling, anyhow.

As you describe it, one conductor makes cash deposits into multiple accounts of the same entity totaling over $10,000 in cash. You don't say anything about multiple locations or multiple DBAs of the one entity.

Let's say the deposits are $3,000 each into four accounts of the entity.

You would have one Part I section for the conductor and one Part I section for the entity.

The info on the entity would include its headquarters address and its EIN and identification information, along with any contact into (phone number, email address) for the entity.

You would include each of the four account numbers and the full $12,000 amount in item 21, and check the multiple transactions box (item 3), and box 2c.

Yes, that is similar to my scenario.

This particular business is a mom & pop grocery store, registered MSB that cashes customer checks. If this same conductor who made the deposits also cashes a check on the business for the business benefit, does that require a separate Part 1 page for the conductor and the entity, or is that under the suspended change and I'm permitted to use one Part 1 page, reporting both the cash in/account #s and the cash out/account # as I have in the past?

The role is the same. The transactions are conducted by the person (item 2b) on behalf of the entity (Item 2c). If the cash out also exceeds $10,000 then you can list the applicable account numbers and amount for cash out in Item 22 on the same Part I.

Thanks for the confirmation

Does someone have a link to guidance on this new rule? my understanding is the rules were postponed indefinitely and we have not received or seen anything saying different. Thank you

The ruling is here: https://www.fincen.gov/sites/defaul.../2020-02-10/FinCEN_CTR_Form112_508_1.pdf

The postponement is here: https://www.fincen.gov/news/news-re...k-provides-further-information-financial

We should remember that, if and when FinCEN lifts the suspension of FIN-2020-R001, there may be changes prompted by comments and questions raised before the suspension was announced. We will be watching for any movement on the ruling here at BOL and will include any news in our Top Stories and Daily Compliance Briefing.

I agree, John, that there very well could be changes due to the questions raised before the suspension was announced. It will be interesting to see what they do.

How many Part 1 2b pages are now required for one conductor, transacting on behalf of 3 entirely different businesses, 3 different business names, IDs, EINs, account numbers under this new rule? I know I need the separate Part 1 2c page for each business for what was done with their specific account. I am thinking I need 3 Part 1 2 b pages for the conductor, one for each business? Is that correct or do I list all 3 account numbers and total cash in on one Part 1 2b page for the conductor as I did prior to this Sept 1 rule change?

Multiple part I's for the same person apply if they have different "roles" in the transaction(s). Since the person's role in all the transactions is 2b, then only one part one is needed. If the person had also deposited funds into their personal account, we would have needed an additional part I for them using role 2a since they conducted a transaction on their own behalf.

We have a hotel holding company that deposits funds for 4 different hotels into the same account. Each hotel has a different address, but the only address we have on file is the holding company. Each deposit slip lists which hotel the funds came from. In this scenario, I am assuming we only file one Part I for the holding company and all cash deposited into their one account? Since we do not have an account for each hotel location/entity I do not think it should be broken out into multiple Part I's. Thoughts?

Depends on if the separate hotels are actually separate entities. If they are, then this account arrangement is likely not set up correctly.

After some clarification from our commercial lender, there are 2 real estate holding companies that each own 2 of the hotels, the deposit account is the operating entity

So, for example, REIT A owns Hotels A and B and REIT C owns Hotels D and E, but Entity F (an LLC or a corporation) operates all four hotels?

Do all four hotels have the same name?

Yes to your first question John, entity F is operating all 4 hotels. No to your second question, they are all different chains ex hilton, hampton, holiday inn, motel 8.

OK. If they are all being operated by the same entity, even if they fly different chain flags, they can all deposit to the same account. At some point, though, if FinCEN reactivates its February 2020 CTR ruling, you will have to do a separate Part I for each location, plus one for the entity that summarizes them all.

OK. If they are all being operated by the same entity, even if they fly different chain flags, they can all deposit to the same account. At some point, though, if FinCEN reactivates its February 2020 CTR ruling, you will have to do a separate Part I for each location, plus one for the entity that summarizes them all.

Thank you John and Randy, as always i appreciate the feedback!