Do you all complete a DOEP for all possible Phase I exemptions, even if they haven't had a CTR filed on them? Or do you wait until they need a CTR filed and then exempt them?

For example: XYZ Corp is a publicly traded company. They often hit my report with large cash deposits/withdrawals, but have never had any cash transactions over $10,000. Go ahead and exempt them since they are eligible, or wait until you need to exempt them?

Thanks!

Negative. You can wait. If and when they have a > 10K Cash transaction you can file at that point. You have to file within 30 days of the first transaction that you want to exempt.