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#2022445 - 06/24/15 01:33 PM Exempt List
peony Offline
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peony
Joined: Mar 2013
Posts: 250
Is the exempt list (for a phase II) at the customer level or account level? If one account meets the qualifications during the review, does only that account get exempted or do all accounts for that customer get exempted? Thoughts?

Thanks!

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#2022492 - 06/24/15 02:30 PM Re: Exempt List peony
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
I believe the exemption is at the customer level, but only for transaction accounts (incl. MMDA).
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#2023630 - 06/28/15 09:58 AM Re: Exempt List peony
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The exemption includes all accounts that you incorporated in your review in order to conclude that the customer "frequently" has large currency transactions. If you initially and annually review them all, then the customer itself is exempt. Question 13
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