No. But the more you can demonstrate you know about your customer, the easier justifying your exemption will be. For example, if you exempt a chain of Dunkin' Donuts franchise stores (single ownership), examiners will want to know how you review the relationship each year. One of the things you'll want to know is how many donut stores deposit with you (to warrant the huge amounts of cash).
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8