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.