CTR Reporting - IOLTA Accounts

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Question:

We have several attorneys who maintain IOLTA accounts with our bank. They all use the same tax ID and their transactions aggregate on the large cash transaction report. If they are acting independently, would we still need to aggregate the transactions for CTR reporting?

Answer:

No. You may have the same TIN, but that belongs to the State Agency that is only receiving the interest payments.

First published on BankersOnline.com 5/18/09