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#321419 - 02/24/05 03:38 PM Designation of Exemption
Anonymous
Unregistered

We have a business customer that really needs to be exempted from CTR reporting, however a couple of years back they were not in good standing with the state. For the last two years however, they do have a good standing report. Is there any reason why I should not go ahead and file for an exemption for this business???

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#321420 - 02/24/05 03:49 PM Re: Designation of Exemption
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
What is the nature of the business?

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#321421 - 02/24/05 06:14 PM Re: Designation of Exemption
Anonymous
Unregistered

It is a convenient store.

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#321422 - 02/24/05 06:40 PM Re: Designation of Exemption
rlcarey Online
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rlcarey
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Posts: 83,227
Galveston, TX
While whether or not the business is in good standing with the State might be a step in your due diligence process in granting exemptions, it should not be a determining factor for an exemption. There are many factors that you have to analyze - the least of which is whether they are laundering money.
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#321423 - 02/24/05 06:45 PM Re: Designation of Exemption
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
I would not exempt a convenience store. They are too high risk.

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#321424 - 02/24/05 06:48 PM Re: Designation of Exemption
Anonymous
Unregistered

There is no money laundering going on. I should also state that this business has been exempted before by our bank, but their exemption was revoked when the annual review revealed that they were not in good standing with the State. Like I said this was three years ago, and over the past two years they have shown to be in good standing.

Should it matter that we have revoked them in the past????

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#321425 - 02/24/05 06:53 PM Re: Designation of Exemption
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
I think it matters that you revoked them in the past.
I think not keeping your State registration current (is that what you mean by 'not in good standing with the State?')- is a sign of sloppy management and a disregard for procedures. IMHO.

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#321426 - 02/25/05 10:51 AM Re: Designation of Exemption
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
How much CTR filing cost will you save with the exemption? (Cost of producing and filing one CTR times the number of CTRs you filed during the most recent year included in your review.)

How much time and cost does it take to create and document the exemption, train and retrain staff about what is exempt and what is not, conduct internal reviews for compliance with your exemption decisions, defend the exemption during BSA inquisitions by examiners, and monitor the exempt customer?

Unless the difference is substantial, forget the exemption - you're kidding yourself about the risk/reward ratio.
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