Skip to content
BOL Conferences
Thread Options
#1418007 - 07/21/10 05:02 PM Govt entity - exempt?
morirse de risa Offline
100 Club
Joined: Feb 2009
Posts: 238
Midwest
It's fair time and we have 2 County Ag Societies that we usually end up filing a bunch of CTRs for.

Would a entity of the County be a department or agency of the U.S., any State, or any political subdivision of any State?

Initially I thought so but now I'm second-guessing myself...

Return to Top
BSA/AML/CIP/OFAC Forum
#1418086 - 07/21/10 06:03 PM Re: Govt entity - exempt? morirse de risa
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
We have the same situation and we have always included them in our CTR filing. They have a different EIN then all of the other county related accounts, so we don't exempt them. Maybe they should be? No one has ever said anything regarding this.
_________________________
My opinion is mine only- not my employer's!


Return to Top
#1418284 - 07/21/10 09:22 PM Re: Govt entity - exempt? J2C
morirse de risa Offline
100 Club
Joined: Feb 2009
Posts: 238
Midwest
Any ideas on what type of document(s) I would need to prove that they are a govt entity?

Return to Top
#1418422 - 07/22/10 01:23 PM Re: Govt entity - exempt? morirse de risa
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Best guess is that they are not actually part of the county's organization structure. They may receive county support, but you probably can't call them part of county government.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1418592 - 07/22/10 03:36 PM Re: Govt entity - exempt? John Burnett
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
As John said, I don't think they are. If they were associated with the county, they most likely would have the same EIN.
_________________________
My opinion is mine only- not my employer's!


Return to Top
#1418916 - 07/22/10 07:49 PM Re: Govt entity - exempt? J2C
TMichelle Offline
100 Club
Joined: Jan 2009
Posts: 106
What is an Ag Society?

Return to Top
#1420213 - 07/27/10 03:17 PM Re: Govt entity - exempt? TMichelle
morirse de risa Offline
100 Club
Joined: Feb 2009
Posts: 238
Midwest
Just talked to FinCen and they told me that I could exempt the County Ag Societies as they are entities acting with government authority.

Return to Top
#1421079 - 07/28/10 07:45 PM Re: Govt entity - exempt? morirse de risa
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Hmmm. That kind of surprises me. I'd keep a record of whom you spoke to at FinCEN if I were you. I googled "County Ag Society" and came up with a lot of websites. Most suggested that the primary business of these groups is to promote agriculture within the county and to put on the annual county fair/rodeo. I even found the Burnett (WI) County Ag Society, way up in northern Wisconsin. Now THAT was a surprise!
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1421266 - 07/29/10 10:08 AM Re: Govt entity - exempt? John Burnett
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
I agree with John. I would be looking for a direct link to the county government and make sure that they are not really a 501(c)(3) type organization.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z