Need a second opinion:

One of our deposit customers is a payday lending, small loan lending, auto title lending company. As such, I believe they qualify as a Non Bank Financial Institution. They are very cash-intensive and we do file CTRs as necessary. They are also registered with FinCEN as an MSB for check cashing, issuing MOs, money transmitting.

Do I read the regulations on CTR Exemptions correctly that we cannot exempt these type of organizations? Are they considered ineligible because they '...serve as a financial institution...'?

Thanks.

Correct. This customer cannot be exempt from CTR filings.

If more than 50% of their revenues come from serving as a non bank financial institution, you cannot recognize them as a phase II exempt person.

See also Question 17

Thank you both for confirming my interpretation. Much appreciated!