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#2066606 - 02/29/16 06:20 PM CTR exemption revocation
Midwest BSA Offline
Joined: Sep 2014
Posts: 54
I know that we don't have to file a revocation for a CTR exemption, but I've read that many people do because it looks cleaner. Is it a good idea to file a revocation on a local municipal government? They haven't had any cash activity lately, much less anything CTR-worthy. It would make our review process easier and make our files look cleaner if we got rid of their exemptions. So would you just put a note in the file about your reasoning on why it was revoked or officially revoke it?

Thank you!

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#2066611 - 02/29/16 06:23 PM Re: CTR exemption revocation Midwest BSA
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 79,310
Galveston, TX
There is no requirement to submit an exemption for a governmental agency or even do an annual review, so there is nothing to revoke.
The opinions expressed here should not be construed to be those of my employer:

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#2066652 - 02/29/16 08:03 PM Re: CTR exemption revocation Midwest BSA
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,630
Cape Cod
Put another way, government agencies are exempt by regulation. You don't bestow exempt status on them. They are just exempt. You would stop treating them as exempt if an when you determined the agency doesn't exist any longer. Not a likely turn of events.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2066718 - 03/01/16 11:53 AM Re: CTR exemption revocation Midwest BSA
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Your source of confusion may be that you actually filed a required DOEP on the government entity. In 2008 or earlier, it was required. Now it isn't. FIN 2012 - G003

As noted, today banks and government entities are simply exempt from CTR filing; i.e. it is simply wrong to file a CTR on a bank or a government entity. Thus, filing exemptions or revoking them is a moot point on this specific type of exempt person.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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