Be Exempted from CTR filings? We have a client we audit that has provided an exemption to a Check Cashing business. I looked at the ineligible's on the form but there is no specific mention of this. Help....

I know there is debate on this issue, but we have a few that are exempt. I believe that as long as the gross sales from the MSB activity is less than 50% of their total gross sales, the customer may be exempt.

If the business's primary activity is check cashing (sounds like it based on your question), it is classified as a non-bank financial institution by the regulation, and is not eligible for an exemption unless it happens to be a "listed company," which is almost beyond the reach of expectation.

Thanks! It justed seemed strange that with all the concern over these entities a bank would exempt them. My first thought is it could bring undue critisism and scrutiny of the over all BSA program. We just want to make sure we are giving the correct information to our clients.