Benefiting Client's Info On CTR (IOLTA)

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Question:

When filing a CTR on an IOLTA account, do I need to include the benefiting client's information on the CTR if the Client is incapacitated?

Answer:

Incapacity should be irrelevant to the CTR filing requirement. If a reportable cash transaction involves an IOLTA or other account held in a fiduciary capacity, it should include information on all persons on whose behalf the transaction is completed. For an IOLTA, that includes the attorney or law firm and its client(s). And of course, the conductor of the transaction is also reported if not one of the persons on whose behalf it was conducted.