The bank is filing a Currency Transaction Report (“CTR”) for transactions of a Parent Teacher Organization (“PTO”). The PTO uses the EIN of the Catholic elementary school it is affiliated with. What entity name, tax identification number, and NAICS code number should be used on the CTR?
Since the PTO is using the EIN of the Catholic elementary school, this indicates that it has not been organized as a separate organization or applied for 501(c)(3) tax exempt status, since having its own EIN would have been required in that process. In effect, it is part of the school and a name the school does business as.
Under guidance issued by the Financial Crimes Enforcement Network for legal entities operating under a “doing business as” name, the name, address, EIN, business activity, and NAICS code of the school would be used to complete Part 1 of the CTR, with the name of the PTO appearing in box 8, “Alternate Name.” FIN-2008-R001; “Frequently Asked Questions Regarding the FinCEN Currency Transaction Report (CTR),” April 1, 2013, Question 26.