When exempting a Phase II non-listed business, at what point can the exemption form be filed? Should it be filed after the 5th CTR is filed (when the 6th reportable transaction occurs)or can it be filed in lieu of the 5th CTR?

Eligibility for exemption is based on the number of large transactions conducted, not the number of CTRs filed. The customer is eligible after the fifth transaction and filing the DOEP eliminates the necessity of filing CTRs for the preceding 30 days.

You might file fewer than five CTRs...