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#2211444 - 04/17/19 07:22 PM Phase I exemption
GrannieTwo Offline
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First DOEP ever, so I'm sorry that my question by some will make them think OMG, but here goes. In the last week of April this year, our bank will begin an account relationship with a company traded on the NYSE. I believe I'm correct that I'll have to complete and send in a DOEP but I'm thrown by that I have 30 days after the first reportable transaction that was exempted to file. What if the account is open for six months before the first reportable transaction was made? I'm correct that the 30 days starts from that transaction, right? Because the company is a Phase I, is only one transaction required to file a DOEP? As I said, this is the first time I've have had to file a Phase I DOEP and I don't want to get it wrong. Thanking anyone for their help.

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#2211461 - 04/17/19 08:04 PM Re: Phase I exemption GrannieTwo
BrianC Offline
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"Banks must file a one-time Designation of Exempt Person report (DOEP) to exempt each eligible listed public company or eligible subsidiary from currency transaction reporting. The report must be filed electronically through the BSA E-Filing System within 30 days after the first transaction in currency that the bank wishes to exempt."

If the first transaction is June 1, 2019, file your DOEP by June 30, 2019 and you're good to go.

You also must perform an annual review on the exempt customer to verify that they are still publicly traded. (If they are delisted you would have to revoke the exemption.)
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#2211462 - 04/17/19 08:05 PM Re: Phase I exemption GrannieTwo
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#2211610 - 04/19/19 01:47 PM Re: Phase I exemption BrianC
GrannieTwo Offline
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Central IL
Thank you. So if it is days, months or years, it is 30 days after the first $10,000+ deposit, correct?
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#2211691 - 04/19/19 08:23 PM Re: Phase I exemption GrannieTwo
TryingtoComply Offline
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Yes

The report must be filed electronically through the BSA E-Filing System within 30 days after the first transaction in currency that the bank wishes to exempt.
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#2211708 - 04/22/19 01:20 PM Re: Phase I exemption GrannieTwo
bcompliance Offline
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Just to clarify - if the customer has had an account with you for 5 years and their first reportable CTR was 4 years ago, and you didn't exempt them at that time, you can still exempt them within 30 days of the next reportable transaction. So if you had one last week, you still can exempt them within 30 days of that transaction.
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#2211709 - 04/22/19 01:28 PM Re: Phase I exemption BrianC
MScarn6942 Offline
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Land Lacking in Lakes, IL
Originally Posted By BrianC
You also must perform an annual review on the exempt customer to verify that they are still publicly traded. (If they are delisted you would have to revoke the exemption.)


In your scenario where they become delisted, how soon after the revocation of the Phase 1 exemption can you exempt them as a Phase 2 exemption (assuming they meet Phase 2 criteria)?
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#2211710 - 04/22/19 01:39 PM Re: Phase I exemption GrannieTwo
rlcarey Online
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Immediately, you already have the required data and history.
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