I have been asked to consider a local Electric Membership Corporation for CTR exempt status. The company does not meet the 12 month deposit account relationship requirement, so my initial response was that we could not grant an exemption. A 'business banker' w/in our bank has asked that I give this more consideration and look into whether or not there have been some special rulings regarding exemptions for these types of businesses, as this will be a 'million dollar' account relationship once they have moved all of their accounts over to us. She is certain that the issue must have been addressed before considering the number of electric memberships out there!

I came into BSA after Phase II exemptions were implemented and have not heard of any options to make a special request for exempt status for customers that do not meet the standard exempt qualifications. Is there such an option available to us? Is anyone out there familiar w/any prior rulings regarding this matter?

Any assistance is greatly appreciated.

God bless the "business bankers" who want to make things all warm and cozy for their clients.

No, there has not been an exception created for "these types of businesses." Unless the Corporation qualifies for a Phase I exemption (is it somehow a unit of local government? I think not), its exemption will have to wait for 12 months like all the "little" businesses that your business banker doesn't bend over backwards for.

I seriously question whether an electric membership corporation would generate large amounts of cash warranting CTR filings, anyhow. And if I misunderstand the nature of this business and they do generate (pardon the pun, please) gobs of cash, what do they care? They don't fill out the CTRs; your tellers do, and it won't take them long to have a template made up so all they need to do is fill in the cash amount and date. They'll even have transactor information pre-filled once they know the cast of characters that show up with deposits.

Keep an eye on the business banker. He or she could spell trouble, with a capital T.

Is it possible the customer requested the exemption? If so, I would look into the situation further to see if a SAR is warranted.

Unless you can figure out how they fit into a Phase I exemption - there is no exception process from the requirements for Phase II customers. The 12-month rule is a hard and fast rule.

No surprises here! It is exactly as I thought. Thank you all for your quick responses!!

This was very helpful to me as this question came up today. Thank you all, as always.