Can a church be on the CTR Exempt List if they have the meet the guidelines of number of transactions?

Here is a copy of the list of ineligible exempt persons:

(8) Ineligible businesses. A business engaged primarily in one or more of the following activities may not be treated as a non-listed business for purposes of this section: Serving as financial institutions or agents of financial institutions of any type; purchase or sale to customers of motor vehicles of any kind, vessels, aircraft, farm equipment or mobile homes; the practice of law, accountancy, or medicine; auctioning of goods; chartering or operation of ships, buses, or aircraft; gaming of any kind (other than licensed parimutuel betting at race tracks); investment advisory services or investment banking services; real estate brokerage; pawn brokerage; title insurance and real estate closing; trade union activities; and any other activities that may be specified by FinCEN. A business that engages in multiple business activities may be treated as a non-listed business so long as no more than 50% of its gross revenues are derived from one or more of the ineligible business activities listed in this paragraph (e)(8).

So, unless it's Bob's Church and Pawn where more than 50% of the revenue is from the pawn side, you can't exempt the church. On the other hand, if it's a small church in the country, with a small congregation, you'd have to wonder how they frequently deal in amounts > $10,000.

Based on prior conversations with the Help Line (which you should confirm on your own dime then write a memo to file) a church would be treated as a "non listed business" and can be recognized as such if they meet the requirements.

We have had a few large churches on our exempt list for many years without a peep from an examiner or auditor. To SLU Voice: didn't you mena to say that you could exempt the church?

Nope. I said if they derive more than 50% of their revenue from the pawn side, then they couldn't exempt the church. Just trying to use humor. I've never actually been to Bob's Church and Pawn.

Maybe a more realistic example depending on the denomination. How much of their revenue is derived from raffles/and or bingo?