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Personal Rep Acting On Own Behalf Or Deceased

An account holder is deceased. An individual is named the personal representative by the court. Pers. Rep. B closes the account of deceased and in the process withdraws $20,000 cash. CTR filing is required. Did Pers. Rep. B act on own behalf, or on behalf of another (deceased account holder)?

Answer by John Burnett: Since the Personal Representative can only withdraw funds from the account in his/her capacity as Personal Representative, the transaction was completed on behalf of the Estate of the deceased individual (not on behalf of the decedent), the Personal Representative is the individual who conducted the transaction on behalf of the estate.

Don't forget that the Estate must have an EIN. You can accept neither the SSN of the decedent nor the SSN of the personal representative for the section of the CTR about the Estate.


Answer by Ken Golliher: Personal representatives do not deal in cash. They have a responsibility to account for every dime they handle and they cannot do that by making cash withdrawals. I would like to know a bit more about the circumstances, but in your shoes I would be giving more thought to how I was going to fill out the SAR rather than the CTR.

First published on 5/13/13

First published on 05/13/2013

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