Alert! CTR Changes on Sole Proprietors and Legal Entities

Program Update - as of April 3rd, 2020, FINCEN has delayed the new CTR filing obligations. This program will briefly cover what is existing and go into further detail on what is delayed.

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.

The webinar will go line by line through the CTR. You will learn how to avoid pitfalls and common errors.

These errors can cost you time and penalties in corrections. You will receive a large handbook of common scenarios at your financial institution plus you will be trained on the latest instructions and interpretations.

Covered Topics

  • The four key sections of the CTR
  • Review which data fields are required and which are not required
  • Learn about NAICs codes and their use in the new CTR
  • Understanding and using the FinCEN directed back filing box
  • How to fill out the new CTR on Sole Proprietors, LLCs and Joint Accounts
  • How to fill out the CTR on IOLTAs, POAs, and all the hard fiduciary accounts
  • Examples of the new CTR—Over 20 examples of the CTR
  • New rules on multiple roles on joint accounts

Changes that will be covered:

  • Sole Proprietorship with husband and wife
  • Sole Proprietorship with one DBA and with multiple DBAs
  • Sole Proprietorship with no DBA
  • Legal Entities when to use a home office address and then local addresses
  • Legal Entities with multiple

Who Should Attend?

This webinar will benefit CTR Managers, BSA Officers, Tellers, Deposit Operations and Training.