If we completed a Designation of Exempt Person Form TD F 90-22.53 for one of our customers prior to the account being open for 12 months, making that account ineligible for exemption at the time the form was completed, how can i correct this issue. Is there anything i can do now. (acct opened 11-03, form sent out on 03-04

If you re-evalutated them today would they qualify for a Phase II exemption?

Were any CTRs "missed" as a result of the errant filing?

yes, the company is eligible now. The account was opened on Nov 2003.
Begining March 2,2003 all CTRs were listed as exempt so no CTRs were sent since then.

Date is wrong
Begining March 2,2004 all CTRs were listed as exempt so no CTRs were sent since then

I suggest you conduct a documented review of the activity in the account and, if justified, file a DEP now. That filing will be retroactive for CTRs in the last 30 days and will at least "stop any bleeding."

Do not automatically backfile the missing CTRs. You will need to seek a backfiling determination from the IRS.

Don't worry, if you were the only bank to ever do this, they would not have an established procedure for fixing it.