Answer:
The partnership is one "person" under BSA and the individual is another. You do not aggregate deposits made on behalf of two different persons unless they were made by the same person.
One source of your conclusion is self inflicted - you cannot use an SSN on a partnership account; a partnership account must use an EIN. Also, I would not solicit or take advice from a customer about whether CTR filing was required.
First published on BankersOnline.com 1/9/06