Hard to answer without more specifics. If they are using the EIN of the Diocese, I would assume that would be the legal name of the entity and the individual churches would be handled more like a "dba".
How to Complete a CTR for Local Diocese
A question came up during a recent audit in regards to how a CTR would be completed for a local Diocese. This particular Diocese has a few different churches using the same EIN. Our system recognizes large currency transactions that we compare to see if a CTR was completed. My question is, would a CTR be filed on that specific church when deposits of cash are over $10k, or on the Diocese?
First published on 10/18/2020