How to File CTR for IOLTA Unknown Beneficiary

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Question:

A deposit was made into an IOLTA Account, but the lawyer did not tell us who this was benefiting, how do we file the CTR?

Answer:

Start by contacting the law office or attorney to ask for the information needed to properly complete the CTR. You will need all of the information necessary to complete an entry for each person on whose behalf the cash was deposited by the attorney or law office.

Most attorneys understand that there is a legal requirement behind your need for the information. If you are dealing with one of the few attorneys who don't understand the requirement, invite the attorney to research the provisions of subpart H of 31 CFR Part 1010 before he or she refuses to provide the information. There are some daunting penalty and forfeiture provisions there that are likely to "enlighten" and inform the attorney's response.

First published on BankersOnline.com 6/17/13