Must all account signatories be listed on CTR?

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Question:

If there are several signatories on a business (e.g. a store) account, must each signatory be listed in Section A (as a beneficiary) each time a CTR Form 4789 is required due to a transaction of the store which exceeds $10,000?

Answer:

An emphatic "No!"

You separate the entity from the signers. The entity benefits from the transaction, and is listed. The signers don't benefit, since they don't "own" the funds after the deposit is completed. (Even if they own the entity, the entity owns the funds, not the officers/directors/signers.)

First published on BankersOnline.com 6/30/03