I understand your frustration, but I think an annual review is a small price to pay in comparison to the potential penalties for failing to file CTRs on ineligible customers.

First off, I agree whole-heartedly with Retread. We have always considered the annual review requirement to be a two-parter.

IMHO the annual review requirements for phase I exemptions are dramatically easier than phase II. It is typically as simple as pulling out the WSJ and making a copy of the listing for your file.

Another added bonus of phase I exemptions is that there is no biennial filing requirement.