BSA Officer filed a phase II exemption on a business. It was filed within the 15 day window of a reportable transaction....

On day 1, there was a reportable transaction. On day 14, the Phase II exemption was filed on the business that completed this "said" transaction. Teller/BSA officer did not file the day 1 CTR as they were instead filing an exemption...but it took them 14 days to get it done. Is this acceptable? Can the reportable transaction go under the exemption since the exemption was filed with the 15 day window?

Wondering if we should error on the cautious side and late file the CTR?

What 15 day window??

Any bank that wishes to designate a customer as an exempt person must file FinCEN Form 110, Designation of Exempt Person, with the IRS Detroit Computing Center no later than 30 days after the
first transaction to be exempted.

RL...

Compliance is "not my life".

So I defer to you....the 15 days that I mention is 15 calendar days after the transaction that we have to have the CTR filed in.

You did answer my question....If we filed a Phase II exemption 14 days after the reportable transaction, all is kosher.

Thank you sincerely for your help.