Fire department employees collect funds for MDA. Even though department is part of the city, funds have nothing to do with governemnt. File CTR or treat as exempt.

Thanks!

Where are they putting the money?

Assuming there is a question mark in there.

File a CTR. The exemption does not reach transactions done on behalf of others.

FD established a separate account several years ago for this sort of charitable activity.

Well, either the FD is a subdivision of the State or it is not. I see no where in 1020.315 does it mention use of funds. IMHO - If you have the proper documentation that the account was opened with the blessing of the city, transactions in that account are exempt. If the city is not aware of the account and the firefighters took it upon themselves to open the account without official city approval under the city's EIN, you have more issues than just filing a CTR.