can an insurance company or a credit company be exempt from CTR filing. From what I can understand from the FFIEC BSA/AML Examination Manual both an insurance company and a credit (loan/finance company) are considered financial institutions. certain businesses are ineligible for treatment as exempt non-listed businesses 31 CFR 103.22(d)(5)(viii). an ineligible business is defined as a business engaged primarily in one or more of the following specified activitiesL serving as a financial institution or as agents for a financial institution of any type. So does this mean they can not be exempt?