I have a situation where I am now filing CTR exemption forms on customers from years ago (2016 and 2017). These customer would have been exempted in years 2016 and 2017 if the forms were completed in those years. I have guidance from FinCEN that stated that I could do this. The Bank has been filing CTRs on customers that should have been exempted in 2016 and/or 2017. I know that the filing of a CTR would void the exemption. My question is this, Since today I am backfiling CTR exemptions on customers where CTR were filed on, should I file another DOEP form with today's date on it exempting the customers moving forward (Since it is possible that CTR could have been filed when they should have been exempted but not exempted until today for 2016 and 2017) (these customer do meet the CTR exemption requirements for 2018).
Basically, the customers were treated as if they were not exempt and CTRs filed for years 2016 and 2017 but in 2018 the Bank is backfiling the CTR exemption from for years 2016 and 2017.

I'd just file an exemption going from their last reportable transaction that you haven't filed a CTR on yet forward. Why would you backfile a DOEP to 2016-2017 when you've been filing CTRs?

I would agree with bcompliance. Why would you go back since you have already filed the CTRs. Do an exemption now and going forward you don't have to file CTRS on those customers. If you didn't file CTRs in 2016 and 2017, and hadn't filed the Exemption, then you would have a problem.

I agree with both of these above. In a previous life, I only handled CTRs (2,000+ a month). However, be aware that some CTRs must still be filed even on exempt customers (such as currency exchanges and loan payments).

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.

Can you backfile an exemption - I really don't think so. You can file one and that covers any CTR's for 30 days prior to actual filing. But you cannot file an exemption now for CTRs that should be filed in 2016 and 2017.