ALEXANDRIA, Va. — The Financial Crimes Enforcement Network has issued an administrative ruling that clarifies currency transaction report obligations concerning sole proprietorships and companies "doing business as."
NCUA's Letter 08-CU-03, issued last month, called credit unions' attention to FIN-2008-R001 (available at http://www.ffiec.gov/bsa_aml_infobase/default.htm), which replaces FIN-2006-R003.
"When filing a CTR involving a sole proprietorship, credit unions are required to complete one section 'A', containing the owner's name, social security number, home address, date of birth and occupation, as well as the DBA name," NCUA Chairman JoAnn Johnson wrote. "Only one section 'A' is required, even if the business operations have a different address and tax identification number than its owner."
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Concerning DBAs, NCUA said that credit unions are required to complete one section 'A' containing the entity's name, employer identification number, address and business activity, as well as the DBA name.
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