Please confirm -a Phase I Exemption, can be used for bank to bank cash activity (shipments to/from). In the case of cash activity for a respondent bank to a Corresponent or visa versa or from Correspondent to Correspondent, either case, they should file the Exempt Person Form. Transfers to the Federal Reserve Banks, i.e. government does not require this exemption form to be completed.

Correct. You need not file an DEP on the Fed. However, even though domestic banks are automatically exempt under Phase I rules, you must file a one-time DEP on them to avoid filing CTRs.

Thanks John! Now to add to that concern. If a bank has been using another bank for a while and did not file the DEP until now, is there some type of back filing document that also needs to be filed? In other words, Knowing banks are exempt, the bank did not file the DEP and has not filed CTR's what should be done for the past activity anything?