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#1105698 - 01/05/09 10:00 PM Backfiling Determination
TXBSA Offline
100 Club
Joined: May 2006
Posts: 170
TX
I am a new Compliance officer and was hired 2 weeks before an exam... the examiner noted that a Designation of Exempt Person form was never filed for the bank that we get our cash shipments from.
Question: Do I still need to obtain a backfiling determination for the CTR's (about 3 a week for the past ??? years) or do the new changes for Phase I exemptions make getting that backfiling useless? What would you do?

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#1105714 - 01/05/09 10:15 PM Re: Backfiling Determination TXBSA
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,318
Galveston, TX
Get the determination - FinCEN most likely will tell you not to file.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1105866 - 01/06/09 03:03 PM Re: Backfiling Determination rlcarey
TXBSA Offline
100 Club
Joined: May 2006
Posts: 170
TX
Thank you!

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