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?

Get the determination - FinCEN most likely will tell you not to file.

Thank you!