Remember that you don't have to file a DOEP to revoke the exemptions -- you just have to resume filing CTRs on these customers. Once you have filed four CTRs and are about to file the fifth on one of the customers in a 12-month period, you can file a new DOEP to exempt them again.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8