Alert! CTR Changes on Businesses
Webinar | 1 1/2 Hours
FinCEN ruling FIN-2020-R001, effective April 6, 2020 (September 1, 2020 for e-filing batch filers), makes significant changes in CTR filing requirements for transactions involving sole proprietorships and legal entities operating under a “doing business as” (DBA) name. FinCEN states that the changes are being made “to both enhance regulatory efficiency and provide complete and accurate CTR data to law enforcement.” The new ruling rescinds and replaces FIN-2006-R003 and FIN-2008-R001, both of which were based on the old CTR Form 104.
During this webinar we will cover how to complete the CTR for the following Changes. We will provide samples and instructions on all of these different scenarios.
What you will learn:
– When a sole proprietorship is involved, items 4 through 7 and item 17 (name, gender and date of birth) are those of the individual owner.
– In states that allow spouses to jointly operate a sole proprietorship, identify the individual whose SSN is attached to the sole proprietorship
– If the sole proprietor does business in his/her own name, the rest of Part I should reflect the individual owner’s information.
– If the individual owner operates the business under a different name (a DBA name), the DBA name appears in item 8 (alternate name), and complete the rest of Part I (other than items 4-6, 7 and 17) with reference to the DBA name and location of that business
– If more than one DBA business is involved in the sole proprietor’s reported transactions, list only one DBA name in item 8 and complete a separate Part I for each involved DBA business
– The amount and account number(s) in Items 21 and/or 22 will be the amount an account number(s) associated with the specific location for the reported transaction.
– When a CTR is prepared on a legal entity such as a partnership, corporation, or LLC , etc., the Part I section should reflect home office/headquarters data (address, phone number, ID number, etc.) of the entity.
– When multiple entity locations are involved, a separate Part I section should be prepared for each location involved.
– Those additional Part I sections should include the entity’s legal name in item 4 and alternative name, if any, in item 8.
– Only one DBA name per Part I. If multiple DBAs are involved, use a separate Part I for each DBA and no DBA name should appear on the Part I for the home office/headquarters.
– Each of the additional Part I sections will identify the location’s address along with other entity data applicable to that location (phone number, etc.)
– The initial Part I section on the entity home office will show total amount and all account numbers involved in item 21 or 22. The Part I entries for multiple locations will show account number(s) and amounts associated with that location only.
Who should attend? CTR Managers, BSA Officers, Tellers, Deposit Operations and Training
Deborah Crawford is the President of Gettechnical Inc., a Virginia based training company. She specializes in the deposit side of the financial institution and is an instructor on IRAs, BSA, Deposit Regulations and opening account procedures. She was formerly with Hibernia National Bank (now Capital One) and has bachelor’s and master’s degrees from Louisiana State University. She has over 30 years of combined teaching and banking experience.