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Aggregation of Secondary Acct. Holder (BSA)

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I am seeking some advise on BSA regulations around aggregation of secondary account holder. Is it a requirement by FinCEN to aggregate transactions based on secondary relationship between accounts and file a CTR? Example: Joint account relationship Account (A) - Chris (P) / Joe (S) Account (B) - Joe (P) / Brian(S) Chris as a conductor makes 6K Deposit into Act A at Branch X Later, Joe as a conductor makes 5K Deposit into Act B at Branch Y should a CTR be filed considering Joe has secondary relationship with Chris in Account A and ultimately benefits from the deposit made?

There is no distinction between primary and secondary owners of accounts for aggregation of cash transactions for CTRs.

Chris's deposit was made on behalf of each of the co-owners of account A -- Chris and Joe
Joe's deposit was made on behalf of each of the co-owners of account B -- Joe and Brian

A CTR is required because deposits totaling $11,000 were made on behalf of Joe. The CTR will list Chris as conductor for $6,000 on behalf of himself (2a) and Joe as conductor for $5,000 on behalf of himself (2a), plus Brian as a person on whose behalf $5,000 was conducted (2c). The total deposit(s) will be $11,000. Item 3 will be checked.

First published on 07/14/2019

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