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#1772001 - 01/03/13 04:53 PM Can IOLTAS be CTR Exempted?
Madawaska Offline
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Any assistance would be appreciated.

Thanks!

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#1772026 - 01/03/13 05:20 PM Re: Can IOLTAS be CTR Exempted? Madawaska
edAudit Offline
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Ineligible Businesses
Certain businesses are ineligible for treatment as an exempt non-listed business (31 CFR 103.22(d)(5)(viii)). An ineligible business is defined as a business engaged primarily in one or more of the following specified activities:

•Serving as a financial institution or as agents for a financial institution of any type.
•Purchasing or selling motor vehicles of any kind, vessels, aircraft, farm equipment, or mobile homes.
•Practicing law, accounting, or medicine.

http://www.ffiec.gov/bsa_aml_infobase/pages_manual/olm_019.htm
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#1772033 - 01/03/13 05:31 PM Re: Can IOLTAS be CTR Exempted? edAudit
Madawaska Offline
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VA
Thank you for your response EdAudit.

This IOLTA customer account is for a local District Court for a local County Government.

Can this fall under a Phase I designation for "Government Agency"?

The Tax ID # is the state of PA IOLTA Board.

Please help!

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#1772039 - 01/03/13 05:40 PM Re: Can IOLTAS be CTR Exempted? Madawaska
devsfan Offline
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Since all or most of the cash activity in an IOLTA account would be for the benefit of the client of the law firm, with the client identified on the CTR, I cannot ever see exempting an IOLTA.

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#1772042 - 01/03/13 05:45 PM Re: Can IOLTAS be CTR Exempted? Madawaska
edAudit Offline
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I would agrre seit devsfan. The court would be Practicing law (not necessarly getting it right :)).
Last edited by EdAudit; 01/03/13 05:45 PM.
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