The instructions for the filing date say for an initial exemption to enter the date of the first transaction to be exempted. Can I just enter today's date and have the customer exempt going forward?

Thank you.

You can enter a date back to 30 days prior to filing if you so desire.

(c) Designation of certain exempt persons —(1) General. Except as provided in paragraph (c)(2) of this section, a bank must designate an exempt person by filing FinCEN Form 110. Such designation must occur by the close of the 30-calendar day period beginning after the day of the first reportable transaction in currency with that person sought to be exempted from reporting under the terms of this section