CTR FAQs - What is the proper way to complete the FinCEN CTR for sole proprietorships and legal entities operating under multiple DBAs?

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Q:  What is the proper way to complete the FinCEN CTR for sole proprietorships and legal entities operating under multiple DBAs?
 
A:  Institutions can continue to refer to Administrative Ruling titled “Reporting of Certain Currency Transactions for Sole Proprietorships and Legal Entities Operating Under a “Doing Business As” (“DBA”) Name,” FIN-2008-R001 . This ruling replaced the previous ruling entitled Currency Transaction Reports on Sole Proprietorships (FIN-2006-R003). FinCEN does not require a covered institution to complete two Part Is when completing the FinCEN CTR for a sole proprietorship or a business operating under a DBA name. Below are examples of how to complete Part I of the FinCEN CTR for situations similar to those provided in FIN-2008-R001 . (To open the examples, please double click on the embedded icon). (To open the examples, please double click on the embedded icon).
 
Example 1 ctrfaq_ex1.pdf
Jane Q. Smith operates a sole proprietorship that does business under the DBA name ABC Express. ABC Express does not have any employees, so Jane and the sole proprietorship have the same TIN. Jane lives at 123 Home Address Road and operates ABC Express from that location. On February 6, 2013, Jane Smith deposited $12,000 into account #12345. Provided below is a proper way to file a CTR on a reportable transaction involving ABC Express.
 
 Example 2 ctrfaq_ex2.pdf
Jane Q. Smith operates a sole proprietorship that does business under the DBA name ABC Express. ABC Express has several employees, so Jane and the sole proprietorship have a different TIN. Jane’s SSN is 121-21-2121 and she lives at 123 Home Address Road. ABC Express’ EIN is 232-32-3232 and it is located at 456 Business Address Drive. On February 6, 2013, Jane Smith deposited $12,000 into account #12345. Provided below is a proper way to file a CTR on a reportable transaction involving ABC Express.
 
 Example 3 ctrfaq_ex3.pdf
XYZ Incorporated, a beverage wholesaler corporation, operates under the DBA name MNO Beverage. XYZ Inc.’s EIN is 787-87-8787. XYZ Inc. registered MNO Beverage with its own EIN of 434-34-3434. XYZ Inc. is located at 789 Corporate Boulevard. MNO Beverage is operated at 001 Drakes Bill Avenue. On February 6, 2013, John Smith deposited $30,000 into account #34567 of MNO Beverage. Provided below is a proper way to file a CTR on a reportable transaction involving MNO Beverage.
 
FAQs associated with Part II of the FinCEN CTR
 
 
 
ADDITIONAL INFORMATION:
This FAQ was obtained from FinCEN’s website, FinCEN CTR FAQs section, which may be found here: 
 
 

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