CTR Reporting for Sole Proprietorships and “DBA” Entities Summary
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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