I agree with the others that there is no point to "backfile" an exemption (unless you had not been filing CTRs b/c you thought an exemption was in place, as BuckDog pointed out). Exemptions are optional and you chose not to file one back then, but are choosing to file one now.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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