Would a dental practice be considered as "practising medicine" for purposes of determining eligiblity for CTR exemption?

I honestly don't know, but the dentist offices I have visited aren't exactly hotbeds of cash activity. Is it really reasonable for a dental practice to have reportable levels of cash transactions at all?

I agree with John. I've never had a dental practice hit cash levels to even be considered for exemption and we've banked many of them through the years. I would consider excessive cash to warrant additional investigation.

We have a few dentists in certain parts of Queens & Brooklyn who get paid in cash, but no where near the level to trigger a CTR. I'll join in on the chorus and suggest additional due diligence on this relationship.

I should have clarified that this the client has 30+ dental clinics that serve a low socioeconomic group where cash is often the only available form of payment (e.g. no insurance, no bank accounts). The cash volume does not appear excessive based on the client's profile.

Any thoughts on whether they would be considered medical practice for exemption purposes?

I could see both sides of the arguement holding water. I would call the FinCEN Help Line and ask for clarification.

Thanks - I left a message for them and am waiting their response.

Agreed - call FinCEN. Absent clear guidance, I wouldn't exempt, that slope is just too slippery for me!

You could always submit a written request for clarification. This would be the safer course of action. Examiners and auditors can't argue with written guidance. The last time I did this it took about a year for a response.

Heard back from FinCEN and they stated that dentists would not be eligible for exemption. Thanks to all who responded!

It is not uncommon for dentists in certain minority communities to operate on a cash basis for a substantial portion of their customers. This is where the whole "know your customer and their customers" comes in.