Not Renewing Exemption - FinCEN Notification
Answer by John Burnett, BOL Gurus Guru Bios
Question: Do we need to notify FinCEN on the 110 form if we are not renewing a previous biennial renewal of an exempt person or business from large currency transactions? For example, if the account has closed or the business does not warrant exemption anymore.
Answer: The filing of a termination form continues to be optional, although some auditors and examiners may push you to notify FinCEN. Your exemption expires on March 15, if you let it lapse. Simply document the reason the exemption isn't being renewed and start filing any required CTRs. That will require that you pull the exemption off your internal lists or systems.
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