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#1245598 - 09/04/09 05:12 PM CTR EXEMPTIONS, ON WHAT DATE TO FILE?
lpramey67 Offline
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When we decide to exempt a customer, what date do we use for the initial exemption? Is it the date of the fifth transaction, or the one after?

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#1245604 - 09/04/09 05:22 PM Re: CTR EXEMPTIONS, ON WHAT DATE TO FILE? lpramey67
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You use the date you actually send the DOEP in.

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#1245643 - 09/04/09 05:41 PM Re: CTR EXEMPTIONS, ON WHAT DATE TO FILE?
Kelsey D Offline
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Ohio
From the FFIEC Exam Manual...

"After a bank has decided to exempt a Phase II customer, the bank must file an initial Designation of Exempt Person form (FinCEN Form 110) within 30 days after the first customer transaction the bank wishes to exempt."

If the transaction in which I want to begin exempting a customer takes place on 9/4, but I don't get the DOEP mailed until 9/20, I would use the 9/4 date so that any reportable transactions that occur between the 4th and 20th do not require a CTR.
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#1245655 - 09/04/09 05:45 PM Re: CTR EXEMPTIONS, ON WHAT DATE TO FILE? Kelsey D
lpramey67 Offline
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do we use the date of the fifth >10,000.00 transaction, or do we have to wait until the next one?

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#1245700 - 09/04/09 06:12 PM Re: CTR EXEMPTIONS, ON WHAT DATE TO FILE? lpramey67
Elwood P. Dowd Offline
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You do not need to wait until the 6th reportable transaction. The prior responses have explained what date is appropriate for the filing date of the form.
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#1245701 - 09/04/09 06:13 PM Re: CTR EXEMPTIONS, ON WHAT DATE TO FILE? lpramey67
Kelsey D Offline
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Ohio
the fifth
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Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1245799 - 09/04/09 07:18 PM Re: CTR EXEMPTIONS, ON WHAT DATE TO FILE? Elwood P. Dowd
lpramey67 Offline
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nowhere did I see fifth or after, must be blind

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#1245834 - 09/04/09 07:58 PM Re: CTR EXEMPTIONS, ON WHAT DATE TO FILE? lpramey67
Elwood P. Dowd Offline
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I know that something is confused here, but cannot figure out what it is myself. grin

Option #1: If the fifth reportable transaction takes place on September 4 you will file the CTR using that date. You may simultaneously file the DOEP and date it September 4.

Option #2: Should you choose to file the DOEP later, you may use the date you file it.

Option #3: If there is another reportable transaction after September 4 you may date the DOEP as of that later date and file it any time within the following 30 days and avoid filing a CTR on the 6th transaction.
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#1245837 - 09/04/09 07:59 PM Re: CTR EXEMPTIONS, ON WHAT DATE TO FILE? lpramey67
nemsi Offline
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The date of the exemption would be the date of the first transaction to be exempted. If you are exempting after "5" reportable transactions it will be the date of the sixth transaction. If you are exempting after 100 CTRs have been filed, it will be the date of the 101st transaction.

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#1245991 - 09/05/09 02:24 AM Re: CTR EXEMPTIONS, ON WHAT DATE TO FILE? nemsi
rlcarey Online
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Galveston, TX
OK - why does it have to be the date of the first transaction exempted?

As Ken indicates, once the fifth transaction occurs, the customer is eligible for exemption.

If that occurs on September 4th, you can file the designation of exempt person form on that date and all future transactions will be exempt, even if the sixth transaction does not occur until December.
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