Answer:
You should list whoever you know is benefiting from the withdrawal when completing a CTR. If the husband makes any comment about he and his wife heading to Vegas (that's why he needs the money), list them both. If you don't have any information, only list the one present at the time of withdrawal.
In your case, if neither mentioned anything about anyone else benefiting from these withdrawals, you wouldn't file any CTR as each transaction was exactly $10,000 (not reportable). However, you should have a reasonable explanation for these two withdrawals, or you may need to file a SAR.
First published on BankersOnline.com 12/07/09
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