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Need CTR Filing Help

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Question: 
I need help with determining the correct way to file a particular customer's CTRs. We have a customer with two DBA accounts. For example: Jim Shoe Inc DBA Jim #1 and Jim Shoe Inc DBA Jim #2. Each DBA has it's own account number. It is my understanding that we should file a CTR based on the aggregate deposit total for the TIN in this case. If #1 has cash deposits of $5500 and #2 has cash deposits of $6500, then a CTR should be filed. Is this correct? Then, I'm not sure how to prepare the CTR. Should we put Jim Shoe, Inc DBA Jim #1 in Section A on the front and Jim Shoe, Inc DBA Jim #2 in Section A on the back?
Answer: 

You are correct. The two businesses' cash deposits should be aggregated and a single CTR filed, with Jim Shoe, Inc., in Section A. If you review examples 5 and 6 in FinCEN's most recent Ruling on CTRs for DBA Customers, you'll see there are two ways you can complete the CTR.

The first option (as demonstrated in Example 5) includes information on the corporation in Section A, with the DBA names in item 5. There's no need to provide separate addresses for the individual businesses, or separate TINs (if they have them).

The second option (see Example 6) includes a separate Section A for the business. In your case, you'd create three Section A entries: one each for the corporation, the corporation DBA Jim #1, and the corporation DBA Jim #2. In this method, you'd provide the address corresponding to the party being described, along with that party's TIN (if it uses a separate EIN).

First published on BankersOnline.com 5/26/08

First published on 05/26/2008

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