Aggregating CTRs when Separate Businesses have Common Ownership

Aggregating CTRs when Separate Businesses have Common Ownership

The Financial Crimes Enforcement Network (FinCEN) has recently issued guidance (FIN-2012-G001, March 16, 2012) regarding the aggregation of multiple transactions conducted by businesses with common ownership. You need to know how this aggregation is handled by EZTeller.


Workaround:

EZTeller consolidates cash transactions by beneficiaries and by conductors. Additionally, you can set up a table of linked tax IDs so Superview will consolidate multiple transactions (involving multiple TINs) using one Common TIN.

  1. Log into Superview and select the Bank as your working group.
  2. Go to CTR > CTR Main Menu and select Customer Information.
  3. Select Linked TaxIDs and then New.
  4. In the Common Tax ID section, select EIN  and complete the Tax ID Field.

Note: While SSN is an options, only EINs should be used for the common TIN.

  • If this is a new customer, type the Business Name.
  • If you enter a TIN that already exists in the system, Superview will automatically fill in the appropriate fields.
  1. In the Linked Tax ID section, select the tax ID format for the linked TIN and type the EIN or SSN (depending on your selection). This TIN will link to the Common TIN.
  • If you selected EIN, type the Business Name.
  • If you selected SSN, type the Last Name, First Name, Middle Name/Middle Initial.
  • If you enter a TIN that already exists in the system, Superview will automatically fill in the appropriate fields.
  1. When you are finished, click OK.
  2. If Superview does not find a beneficiary/holder record for either or both TINs you entered, a message will appear stating that you must create a new holder record.
  • Click Yes. The New Linked Beneficiary/Holder screen appears.
  • Complete the new beneficiary/holder record. Click OK.
  1. If you have additional TINs to link, you should follow steps again linking these TINs to the Common TIN in Step 4 above.

ArticleNumber:

000065451