Answer:
Randy Carey:
If the individual owner operates under multiple DBAs, then a separate Part I section should be completed for each different DBA involved in the transactions.
https://www.fincen.gov/sites/defaul.../2020-02-10/FinCEN_CTR_Form112_508...
However, this was suspended and no new implementation date has been announced:
https://www.fincen.gov/news/news-re...k-provides-further-information-fin...
Answer:
John Burnett:
Recording multiple DBA names in item 8 has never been officially sanctioned for CTRs. What appears to have happened is someone contacted FinCEN to ask about multiple DBAs and someone at FinCEN suggested that listing the DBAs in item 8, separated by semicolons, would do the trick. Or it may have been a method suggested by someone else.
Regardless, it was not a method approved in the February 2020 Ruling on CTRs for sole proprietors and entities. But, as Randy reminds us, that Ruling was suspended before it became effective, with permission to follow the Ruling if you had already implemented it.
If your bank is still listing multiple DBAs in item 8 in a single Part I for its CTR filings, it hasn't implemented the February 2020 Ruling. So, you should not have a problem if you continue to report in that manner when filing a CTR covering transactions of multiple DBA business of the same sole proprietor. I don't recommend that you invest time and effort in trying to change your reporting routine to conform to the February 2020 ruling, since we don't know if or when it might be reinstated, or, if reinstated, what changes FinCEN might make to address the many questions that have been raised concerning the Ruling in its original form.
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