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#1627604 - 11/10/11 09:32 PM Is it ok for a customer to know they are Exempt?
Likes to Comply Offline
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In the mountains
Is it ok for a customer to know that they are exempt from CTR filings?

If I wanted to request information to determine if a customer's activities might meet the no more than 50% of gross revenues per year from ineligible business rule, can I indicate that it is to determine if they may qualify for exemption?
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#1627610 - 11/10/11 09:37 PM Re: Is it ok for a customer to know they are Exempt? Likes to Comply
Elwood P. Dowd Offline
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Elwood P. Dowd
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It's not a problem...as you note, customer cooperation is oftentimes necessary. If you've filed CTR's on them in the past and simply stop, they will probably notice it anyway. wink
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#1627611 - 11/10/11 09:37 PM Re: Is it ok for a customer to know they are Exempt? Likes to Comply
John Burnett Online
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John Burnett
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There is nothing in the BSA regulations to prevent you from telling the customer why you are asking for the information.

As a practical matter, I cannot imagine how you'd get the information from most customers without explaining your interest, unless the customer happened to borrow from your bank and provided such detail (again, really doubtful) in financial statements supporting the loan.
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#1627619 - 11/10/11 09:45 PM Re: Is it ok for a customer to know they are Exempt? John Burnett
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Thanks for the help!
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