Has anyone been criticized for exempting towing companies? Thank you.

I think the larger question is - how common is cash in the towing business?

I would expect towing companies to be mostly paid with check and debit, and quite often to be paid by insurance companies. If there is a large operation with many trucks that will only do business for cash, I would think you could document their business model and then as long as your due diligence supports your decision you should be able to defend yourself.

We have not had towing companies as exempt customers, but I can relate that I worked part time (up until 3 years ago) in the office of a towing company having worked there six years, and payment was almost always exclusively debit/credit card.

The issue is well formed; cash would be an unusual method of payment for a towing company. I would have sit down with a towing company that was depositing reportable amounts of currency and just chat about their business; e.g. how many calls a day, a week, average fee, etc. If every customer paid in cash, that would still mean 51 $200 tows in a day.

A towing company for semi's and semi tractors might have different sets of numbers and payment methods, dunno.

Make a site visit as well. You'll most likely find they are engaging in other business activities.

We have a "towing company" customer who engages in large cash transactions. After discussions and a site visit, we found he was also operating as a used car dealer under the towing company name. We changed his classification to car dealer (not exempt) and elevated to high risk.