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#1701162 - 05/18/12 04:45 PM CTR Exemptions
Anonymous
Unregistered

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?

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#1701182 - 05/18/12 05:06 PM Re: CTR Exemptions Anonymous
MagicCity Offline

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MagicCity
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Last edited by MagicCity; 05/18/12 05:07 PM.
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#1701227 - 05/18/12 05:49 PM Re: CTR Exemptions Anonymous
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
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Next to Harvey
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#1701242 - 05/18/12 06:13 PM Re: CTR Exemptions Anonymous
Anonymous
Unregistered

Thank you!

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#1702422 - 05/23/12 03:09 PM Re: CTR Exemptions Anonymous
P*Q Offline

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P*Q
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Somewhere
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. smile

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#1702817 - 05/24/12 01:36 PM Re: CTR Exemptions P*Q
Anonymous
Unregistered

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.

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#1702820 - 05/24/12 01:37 PM Re: CTR Exemptions Anonymous
John Burnett Online
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John Burnett
Joined: Oct 2000
Posts: 39,630
Cape Cod
No, it's not necessary.
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#1703156 - 05/24/12 08:19 PM Re: CTR Exemptions Anonymous
Sunshine_101 Offline
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Sunshine_101
Joined: May 2005
Posts: 127
Here is the FinCEN Guidance regarding CTR Exemptions.

Sorry, I didn't see that Ken Pegasus already posted this. wink
Last edited by Sunshine_101; 05/24/12 08:20 PM.
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The postings on this site are my own and do not necessarily represent my employers opinions.

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#1703621 - 05/25/12 08:35 PM Re: CTR Exemptions Anonymous
Anonymous
Unregistered

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.

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