WASHINGTON (1/17/08)--A credit union member withdraws $15,000 in cash from the joint account he shares with his wife. In completing a currency transaction report (CTR), must the credit union list only the individual who made the withdrawal or all of the owners on the account? This question currently is the subject of much debate, according to the Credit Union National Association's (CUNA) Compliance Challenge. For years, financial institutions--both credit unions and banks--were advised to complete CTRs for withdrawals on joint accounts with only the information of the individual completing the transaction, unless there is reason to believe that the other joint owners on the account will benefit from the withdrawal. However, some institutions are being advised to assume all joint owners are benefiting from the withdrawal, which means all should be listed on the CTR form. This latter position appears to be based on an older piece of Financial Crimes Enforcement Network (FinCEN) guidance, which is embedded in an inactive FDIC Financial Institution letter, according to the Challenge. CUNA recently received clarification that the FinCEN guidance remains active and is considered standing authority on this particular issue. The association said FinCEN is expected to issue clarification on this issue in the near future.