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CTR on Deposits in Personal & Partnership Accounts

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Question: 
A customer made an $8,500 cash deposit to his personal account. On the same day a deposit was made into a partnership account, in which the person is a partner, of $3,000. That deposit was made by another partner. Our customer says that although his SSN is used on the partnership account, the money put in by the other partner is that partner's money, not his and therefore we should not file a CTR. Do we file a CTR?
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

First published on 01/09/2006

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