The tax collector for a local municipality deposited >$10,000 to multiple accounts (all set up under the municipality's EIN) on one business day. Real estate taxes are due this month and many property owners have paid in cash.

While I believe the municipality would qualify for a Phase I exemption as a government agency (without the bank having to file a DOEP or do an annual review), is it wrong to file the CTR instead?

Pros and cons to filing or exempting?

Filing the CTR or the DOEP would not be a violation. However, I would analogize it to filing CTRs on amounts below $10,000.01 and critique your training and your internal controls.

It's simply not required...

One of the problems with filing the CTR in this case is that even though the CTR is not required, you are held accountable for the accuracy and correct completion of the filed CTR. It is much easier and preferable, IMO, to treat the municipality as exempt.

Okay, so if I don't file the CTR...what do I need to do since a DOEP is not required?

Is it enough to document on my system generated cash aggregation report that a CTR is not required because the customer is an exempt governmental agency?

Essentially, yes. And, if you have a system or other list of exempt customers, add the municipality to the list.