Does anyone have an exact (or at least close) date when the reg was changed to disallow check cashers and other money services businesses as Phase II exemptions?

Also, be warned that regulators will be expecting you to get with the IRS and backfile CTRs or whatever else is necessary when this comes up. You may already have known this, but I wanted to throw out a waqrning if you did not.

You could not add any exemptions under the so-called "old rule" after 10/21/1998. And all old-rule exemptions had to be converted to Phase II by July 1, 2000, or dropped. Reference is to §103.22(d)(11) of the Treasury's Recordkeeping and Reporting rules (a/k/a BSA regulations).

So, it appears that you might have had an exemption in place under the old rules through June 30, 2000 (if the exemptions was created before 10/21/1998).

I hope this helps you out.