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#1620534 - 10/26/11 07:57 PM Phase II Exemptions
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Joined: Nov 2008
Posts: 1,062
In the mountains
Can all "eligible accounts" for a customer be exempted for CTR purposes if one account has cash transactions in excess of $10,000 or only the "eligilbe accounts" individually that have transactions more than $10,000 in cash transactions?
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#1620618 - 10/26/11 09:32 PM Re: Phase II Exemptions Likes to Comply
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Diamond Poster
Joined: Nov 2008
Posts: 1,062
In the mountains
Maybe I need to ask this differently. If a customer has two DDA accounts and when the cash transactions are aggregated the > $10,000 threshold is met, can this customer be exempted from CTR filing? Or would the threshold have to be met on each individual account?

This is of course assuming all the other criteria for Phase II exemptions is met.
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#1620625 - 10/26/11 09:47 PM Re: Phase II Exemptions Likes to Comply
cbinder63 Offline

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cbinder63
Joined: Dec 2001
Posts: 674
Colorado
The exemption should be by TIN. All exemptable accounts under the TIN qualify.
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#1620940 - 10/27/11 03:50 PM Re: Phase II Exemptions cbinder63
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Posts: 1,062
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Thank you!
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