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#2221344 - 09/10/19 08:24 PM CTR Exemption
Foxware Offline
New Poster
Joined: Oct 2015
Posts: 5
We have a customer that are currently exempt. We are waiting for the customer to provide the remaining documentation so we can finish our due diligence. The DOEP was filed on 09/24/2018. What is our drop dead date for completing our review so this customer can remain exempt?

Thank you.

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#2221348 - 09/10/19 08:56 PM Re: CTR Exemption Foxware
rlcarey Online
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Joined: Jul 2001
Posts: 78,901
Galveston, TX
Prior to filing the exemption?????
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#2221363 - 09/11/19 12:47 PM Re: CTR Exemption Foxware
Foxware Offline
New Poster
Joined: Oct 2015
Posts: 5
This is a newer exemption where the DOEP was filed last year on 09/24. If the customer does not get us the requested documentation, do I start filing CTRs again on 09/25/2019?

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#2221372 - 09/11/19 02:29 PM Re: CTR Exemption Foxware
praBSA Offline
Gold Star
Joined: Aug 2018
Posts: 330
What documentation would you need from the customer?.... Unless your process is relying on them for eligible activity %s of business related to lottery/etc.... I conduct my own review of their accounts to determine that activity. Never had any issues with exams or auditors.

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#2221382 - 09/11/19 03:57 PM Re: CTR Exemption Foxware
Sunshine Lady Offline
Platinum Poster
Sunshine Lady
Joined: Apr 2014
Posts: 622
I do the same as praBSA, because the customer normally does not even know they are exempt. We exempt them based on our review.
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#2221384 - 09/11/19 04:10 PM Re: CTR Exemption Foxware
P*Q Offline

Power Poster
Joined: May 2001
Posts: 8,457
Same as the two above, can't imagine why a customer would hold up an exemption.

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