I saw a Q & A today about CTR Exempt customers. The Guru stated that deposits and withdrawals could be exempt from the CTR reporting but currency exchanges and purchasing of monetary instruments would not. Is that right? We have several customers exempt from CTR reporting - but if they come in with $10,0001 for a currency exchange, that has to be reported?

For Phase II customers that is correct. Only deposits and withdrawals are eligible for exemption. All activities of Phase I customers are exempt.

For those of you who haven't been in banking as long as Randy and I, "Phase I" and "Phase II" refer back to the phase-in of CTR exemptions many years ago. "Phase I" exempt persons are those listed in 31 CFR 1020, section 1020.315(b)(1)-(5): banks (which includes savings associations and credit unions); departments or agencies of federal, state or local government; entities established under federal, state or local laws, or interstate agreements, that exercise governmental authority on behalf of federal, state or local government; companies with equity that trades on a national exchange; and 51% subsidiaries of such companies.

"Phase II" exempt customers are those that require a transaction account relationship, don't obtain more than 50% of their gross revenues from one or more of the "forbidden list," and are incorporated or organized under the laws of the United States or a State, or registered as and eligible to do business within the United States or a State, and meet certain transaction frequency requirements.