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#1833765 - 07/17/13 07:19 PM Recycling Center Company & CTR Exemptions
CantBeShocked Offline
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Does anyone exempt recycling centers? They are high volume cash out - and what I have always understood a concern with regulators for money laundering?

Any other comments or view points would be appreciated.

Thank you.
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#1834102 - 07/18/13 03:32 PM Re: Recycling Center Company & CTR Exemptions CantBeShocked
NotDoneYet Offline
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The OCC would not let us exempt our scrap dealer because they take cars. I'm not sure if its in the same category as your business.
We have a CTR template for ours so its usually a matter of filling in the amount, and it's not time consuming except for counting the cash involved.

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#1834867 - 07/19/13 09:38 PM Re: Recycling Center Company & CTR Exemptions CantBeShocked
CantBeShocked Offline
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Thank you! I decided not to exempt them at this time unless the scrutiny changes from the regulators in the future.
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#1834919 - 07/22/13 12:11 PM Re: Recycling Center Company & CTR Exemptions CantBeShocked
Elwood P. Dowd Offline
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FWIW, I agree with your decision. At one time, scrap dealers were automatically classified as "high risk." While the classification is now more a of judgment call to be made by the bank, a decision to exempt a junk, salvage, or boneyard from currency transaction reporting would be best supported by a sophisticated intra-bank system for monitoring their cash that did not depend on CTR filing.

As for these operations being buyers or sellers of motorized vehicles, aircraft, vessels, etc. I would guess that once the object no longer moves, flies, or floats, the classification no longer applies. (Vehicles, aircraft, & vessels were put on the list 25 years ago because they can cost a lot of money and can readily be converted back into cash after they've been taken out of the country. I don't think that analysis applies to their remnants.)

If I had to make the call I would rely on FinCEN's advice, not that of my regulator. The only answer the regulator could authoritatively offer on the subject would be one they got from FinCEN.
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#1834954 - 07/22/13 01:35 PM Re: Recycling Center Company & CTR Exemptions CantBeShocked
NotDoneYet Offline
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Since exemption isn't a requirement, we are going with what our regulators told us and that keeps us from being drawn into the same conversation every year.

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#1834981 - 07/22/13 02:23 PM Re: Recycling Center Company & CTR Exemptions NotDoneYet
John Burnett Offline
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Originally Posted By: NotDoneYet
Since exemption isn't a requirement, we are going with what our regulators told us and that keeps us from being drawn into the same conversation every year.


Sounds like a prudent choice, and one less thing to be gnashing teeth over.
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#1835170 - 07/22/13 06:27 PM Re: Recycling Center Company & CTR Exemptions CantBeShocked
Neytiri Offline
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We have a metal recycler with high $ cash outs also and have not exempted. We file about two CTRs per week and have a template for them so not time consuming.

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#1835182 - 07/22/13 06:45 PM Re: Recycling Center Company & CTR Exemptions CantBeShocked
JacF Offline

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I've also been given the line that since scrap yards buy cars, they are not eligible for exemption (though personally, I agree with Ken's analysis). So, proceeding on the side of caution, I haven't exempted any of my scrap yards.

If FinCEN ever issues an official clarification that declassifies scrap yards as "buyers and sellers of vehicles", I've got two scrap dealers who produce near-daily CTRs that I would love to exempt...

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#1835216 - 07/22/13 07:41 PM Re: Recycling Center Company & CTR Exemptions JacF
Elwood P. Dowd Offline
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My personal favorite was the examiner who said the bank could not exempt the auto supply store because someone could build a car from the parts!

Geeze, I love my job! wink
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