what is the waiting period before we file for exemption for a customer.

2 months and 5 qualifying transactions. (can file as soon as the 5th is done)

thank you mucho!!

So the customer only has to have had an elegible transactiona account for 2 months as opposed to the previous 12 months. Correct?

Yes, that's correct. And you don't even have to wait that long if you get 5 reportable transactions and "the bank conducts and documents a risk-based assessment of the customer and forms a reasonable belief that the customer has a legitimate business purpose for conducting frequent transactions in currency." [31 CFR Part 1020, §1020.315(c)(2)(ii)]

A bank that wants to take advantage of that special rule ought to have that possibility set out in its BSA/AML policy and exemption procedures, and would probably restrict its applicability to fairly obvious situations (unlisted businesses that are supermarkets, for example).