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Revised FAQs on Joint CTR filings

Answered by: 

If John and Jane Doe have a joint account and only John makes the deposit for $12,000, how many Part Is do you have to complete?

Revisions have been made to FAQ #23

If Jane Smith did not conduct a deposit, but John Smith deposited $12,000 into the joint account, there would only be two Part Is. One Part I would be for John Smith as 2a "Person conducting transaction on own behalf" and entering $12,000 in Item 21 and the account number affected. The other Part I would be for Jane smith, checking 2c "Person on whose behalf transaction was conducted," entering $12,000 in Item 21, and providing the account number affected.

But under the revised FAQ, if she conducted $5,000 and John conducted $7,000 the FAQ says to do four Part I sections. Each person would have two roles.

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First published on 07/19/2020

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