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Include Beneficiary on the CTR?

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A customer opened an individually owned CD and listed a beneficiary. The CD was opened with $13,000 in cash, so we will file a CTR. Does the CTR have to include the beneficiary?

The CD appears to be designated with a POD or ITF beneficiary and such individuals have no ownership claims to this type of account. There is no way to know at the time of the deposit whether the beneficiary will ever see the funds, because your depositor could revoke the POD/ITF designation at will or change the beneficiary at any time up to the time of the owner's death (assuming the CD is even there then). In my opinion, it would be a real stretch to assume that the deposit is being made on behalf of both the owner and the beneficiary. If you feel you have to make that stretch, I don't think anyone could fault your decision to include information on the beneficiary. However, I don't think there's a valid argument that you must do so.

First published on 9/08/08

First published on 09/08/2008

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