We have never exempted customers. I am trying to read through materials explaining the phases and requirements. Does anyone know where I could find clear simple explanations of how to determine and file exemptions?

The FFIEC Manual is a good resource.

http://www.ffiec.gov/bsa_aml_infobase/pages_manual/manual_online.htm

FIN 2009-G003

Thank you!

I'd encourage you to follow through with exemptions! They're easy to file, little maintenence other than annual review for Phase II and it saves a whole lot of staff time preparing needless CTR's.

I am reviewing my Phase II exmptions for the first time this month. Is it necessary to file a new DOEP form electronically? I filed via paper when I first exempted them last year.

No, it's not necessary.

Here is the FinCEN Guidance regarding CTR Exemptions.

Sorry, I didn't see that Ken Pegasus already posted this.

Oh and based on personal experience with the OCC and their interpretations of even the G003 doc that Ken mentions, you will need a minimum of 2 months customer history that can be risk reviewed and possibly shortened that time. But you must still have five (5) CTRs filed. If anyone disagrees on the minimum 5, please chime in. We tried and lost that argument even with a business that simply shuffled ownership percentages (same people), but got a new EIN number and new acct numbers. Same people. No example given in the G003 doc covers our case.