Skip to content
BOL Conferences Top Gun 23
Thread Options
#1494516 - 01/13/11 03:49 PM CTR Exemption File Question
banker1976 Offline
Gold Star
Joined: Nov 2005
Posts: 346
Mid-Atlantic
Let's say a business has been exempt from CTR filings for ten years. You have all the biennial renewals that were required once upon a time, each annual documentation of account review, anything and everything else. Does all of this need to stay in the file for as long as the account is exempt, or can we just have forms and documentation from the most recent annual review? Wanted to see what other bankers do when you have customers who are exempt year to year and have been for many years.
_________________________
CAMS
CAFP

Return to Top
BSA/AML/CIP/OFAC Forum
#1494558 - 01/13/11 04:18 PM Re: CTR Exemption File Question banker1976
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,862
Cape Cod
I'd use the general recordkeeping rule in the regulation and retain the most recent five years' documentation for the exemption.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1494560 - 01/13/11 04:20 PM Re: CTR Exemption File Question banker1976
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
Retention for these documents is five years. I, personally, keep everything, but that's because I deal with a manageable number of exemptions and everything is kept electronically. I have an active folder for each exempt person and add my annual review to it every year. When the exemption is revoked or the account is closed, I simply move the entire folder to an inactive folder.
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

Return to Top

Moderator:  Andy_Z