CTR Reporting for Sole Proprietorships and “DBA” Entities Summary

Updated 08/12/2020

In February 2020, FinCEN issued an administrative ruling to clarify CTR filing obligations when reporting transactions involving sole proprietorships and entities operating under a “doing business as” or “DBA” name. The Ruling was originally set to be effective on April 6, 2020, but FinCEN suspended its implementation “until further notice” due to the COVID-19 Pandemic. As of publication of this summary, the Ruling remains suspended; however, Banks should consider how it will implement the changes when the Ruling does become effective. Please refer to the Action Plan at the end of this Summary for more information.

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