CTR Part 1

Posted By: Banker Forever

CTR Part 1 - 04/02/21 10:15 PM

I've read comments from a post from last year, but wanted to verify what we think is correct in this situation. If a husband makes a deposit to a joint account, is there one Part 1 with 2a checked as person conducting on own behalf, and then one Part 1 on the wife/joint accountholder with 2c checked as person on behalf transaction was conducted (which is the old way of doing it). Or, do we now have to have an additional Part 1 for husband with 2b checked for person conducting transaction for another?
Posted By: John Burnett

Re: CTR Part 1 - 04/05/21 09:04 PM

The old way is still the right way when one joint owner completes a reportable deposit to a joint account. One Part 1 for the conductor with 2a checked, and one Part 1 for each of the other joint owners with 2c checked.

But what if H deposits $5,000 and W deposits $7,000 (both in cash) to their joint account?

In that case, you do four part 1 entries:
  • H 2a with $5,000 in item 21
  • W 2c with $5,000 in item 21
  • W 2a with $7,000 in item 21
  • H 2c with $7,000 in item 21


and $12,000 in item 25

See Question 23 in FinCEN's CTR FAQs HERE. The answer to your original question is in the "note" at the end of the answer.
Posted By: Banker Forever

Re: CTR Part 1 - 04/06/21 01:12 PM

Thank you.