What is the proper way of reporting the beneficiaries of the following cash
in deposits in a CTR. The TIN number for all is the same #11-1111111.
XYZ Corporation (6 accounts*) $11100
XYZ Corporation dba Café,LLC (Acct 9999) $1000
XYZ Corporation dba Bake LLC (Acct 888) $600
* There is no dba in the title of the 6 accounts.
Do I need to report 3 beneficiaries to show the actual amount of cash deposited to the accounts?
Is it okay to report XYZ Corp dba Café LLC (6 accounts including acct #9999) $12100 and XYZ Corp dba Bake LLC (acct #888) $600?
Currently, when we receive a IRS Tax Levy, we look at the Social Security Number or EIN Number on the Levy and the name. We then research this information in our system to see if they have an account(s) and what funds are available to hold on the day the Levy is presented. We base this on the Name and EIN or Social Security Number provided on the Levy. My question is if we perform our search and determine that the primary name and Social Security number on the account does not match the Levy but the person the Levy pertains to is a signer or secondary owner to the account (Joint Account), should we hold those funds? Should this be done even if it's a Business, Minor Account, IOLTA, Escrow etc.? I would think consideration should be given to the relationship the person upon whom the Levy is presented has to the account.
Is there a requirement to run an OFAC check on a DBA? For example, John Doe DBA ABC Store. Do I need to run an OFAC on John Doe and ABC Store, or simply John Doe?
When the owner of a DBA dies, are the authorized signers still authorized to sign? The account uses the deceased owner's social security number.
We have completed our CIP on the customer opening the account as a DBA, would we still need to complete a CIP on their business? If so how would we do that?
A customer has a DBA sole proprietorship using his social security number. Are there any regs, etc., that say it cannot be in a "personal type" checking account? We only have a "commercial account" and nothing for the small "mom and pop" type of business.
I have been in banking for awhile and am being told I am making a mountain out of a mole hill. When it comes to DBA accounts, I have one opinion on what purpose/style account should be opened and I am being told by others that I am not correct. There are two differing opinions when we open a DBA account. For example, one opinion is that Mickey Mouse DBA Great Escape Mousetraps should be opened as a personal style account, where at the account maintenance level, the code would indicate consumer for the purpose of household or personal use. The other opinion is one in which it should opened as a business style account, where at the account maintenance level, the code would indicate business for the purpose of business. The reporting tax ID number in both situations would be the customer’s Social Security Number. If I understand correctly, there are different regulations regarding the purpose/style of an account and there are different protections and benefits for each purpose/style. Can you please help as to which purpose/style would be proper? My best interest is doing things the correct way for the both the bank and the customer.
I understand that there was a recent CTR filing ruling from FinCEN regarding DBAs. Where can I find this?
The bank has received a levy for a taxpayer. The name on the levy is styled as: John Doe DBA Doe's Auto Sales. The tax id number on the levy is an EIN, not John's SSN. We do not have any accounts for the business, but we do for the owner, in his social security number. Does the levy on the business extend to his personal account since it is a DBA?
We have to file a CTR for a cash deposit to an account of a single member LLC that uses its member's Social Security number instead of an EIN. Should we use the 2008 DBA ruling from FinCEN as a "go by" to complete the CTR?