Q: What amount gets listed in Item 21/22 when the person in Part I was both a conductor and had transactions conducted on his or her behalf?
A: Scenario: Tom Doe deposited $6,000 into his personal account. During the same business day, Jane Smith deposited an additional $5,000 into Tom Doe’s personal account.
In this scenario, the filing institution would complete two Part Is, one for Tom Doe and one for Jane Smith. The Part I for Tom Doe would be completed by checking 2a “Person conducting transaction on own behalf” and entering $11,000 into Item 21. The Part I for Jane Smith would be completed by checking 2b “Person conducting transaction for another” and entering $5,000 into Item 21. For each Part I, the amounts in Item 21 and/or 22 (depending on whether the report is for cash in, cash out, or both) should be the total amount of all cash-in and/or cash-out transactions reflected in the FinCEN CTR involving that individual or entity.
This FAQ was obtained from FinCEN’s website, FinCEN CTR FAQs section, which may be found here: