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.
Members Can Download This Tool
Login to Download
Not Yet a Member?
Our members enjoy:
On-demand regulatory guidance hotline – by chat, phone and email – available from anywhere, on any device – 7 am - 6 pm, M-F, Central time
Research time saved daily & weekly across forms, checklists, and trainings — for every regulation
Hours of form-building and branding of bank documents saved; in some cases, even the budget of additional staff
A sounding board for support and reassessment when institutional goals or the regulatory environment changes
Access to attorneys and compliance specialists for risk modelling and decision-making in advance of large business decisions
The knowledge that C/A was created and owned by 30 State Bankers Association to provide bank compliance services to their membership organizations
Find out how a personalized team of attorneys and compliance professionals helps build targeted compliance strategies throughout your institution when you take our Live Membership Demo.