I have worked at banks where an exemption for a business included all deposit relationships for that business. I have also worked for banks where the exemption is at the account level, thus a business may have three transaction accounts but only one is considered exempt from CTR reporting. I would like to know how most banks handle the exemption process for multiple accounts. Your input wopuld be greatly appreciated.
Below is and excerpt from the FINCEN:
[url=http://www.fincen.gov/news_room/rp/advisory/pdf/advis10.pdf][/url]
Question #13
Is a bank required to treat all transaction accounts of a customer as a single account for purposes of determining the qualification of that customer as an exempt person?
No. A bank may, but is not required to, treat all transaction accounts of a customer as a single account for purposes of determining whether that customer qualifies as an exempt person, as defined by 31 CFR 103.22(d)(2). Treatment of multiple accounts as a single account must, if adopted, be continued. For example, a bank that chose to treat all of a customer’s transaction accounts as a single account would combine the transaction history of the accounts to apply the requirement that a business must frequently
engage in transactions in currency in excess of $10,000 in order to be treated as non-listed business customer, but it would then be required to exempt all such accounts, not simply one of them. Whatever treatment a bank adopts for multiple accounts, the ineligible business activity rule described in Q&A #9 above applies on a customer-wide basis (gross revenues per year).