My question is in reference to 31 CFR 103.22(d)(vi)
A long time customer of ours has two accounts; one is a dda, the other a MMDA (a non transaction account). Both have been exempted, though most of the cash flows through the dda.
The first sentence of (d)(2)(vi) seems to limit the exemption because of the phrase, "...and only with respect to transactions conducted through its exemptible accounts..." but subparagraphs (A) and (B) seem to state that as long as they have kept a transaction account for 12 months and frequently engaged in cash transactions > $10,000 that the "person" is exempt.
Is it ok to exempt both accounts even though the cash generally goes through the dda? (e.g. are we exempting persons/entities or accounts?)