ALEXANDRIA, Va. (3/11/08)—The National Credit Union Administration (NCUA) recently offered currency transaction report (CTR) guidance on filing obligations incurred when a credit union reports transactions involving sole proprietorships and legal entities operating under a “doing business as” (DBA) name. The NCUA Letter No. 08-CU-03 is a follow up to a Financial Crimes Enforcement Network (FinCEN) clarification on the same topic. The FinCEN administrative ruling FIN-2008-R001 replaced a previous ruling, FIN-2006-R003. According to the NCUA letter, FinCEN defines a sole proprietorship as a business in which one person owns all the assets and owes all the liabilities. “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,” the NCUA letter noted. It added that only one section ‘A’ is required, even if the business operations have a different address and tax identification number than its owner. The letter further stated that the FinCEN ruling also applies to CTRs filed on legal entities operating under a DBA name. “Credit unions are required to complete one section ‘A’ containing the entity’s name, Employer Identification Number (EIN), address and business activity, as well as the DBA name,” the letter said.