I feel stupid for asking this question, however, We have a customer that is a subsidiary of a listed company and I want to add them to our Exempt list. I know to file the Designation of Exempt Person form but do I also complete a CTR for the transaction that just occurred and send them in together or separate or just send in the Exempt form?

Confused

If the customer qualifies for a Phase I Exemption, I would file only the Designation of Exempt Person form and no CTR.

My opinion only; not legal advice.

If the customer is elligible for phase I exemption, make sure the effective date is either the same or before the date of the transaction that you are not filing a CTR on.

Although I suggest that you file the Phase I exemption first, it is not a requirement:

31 CFR 103.22(d)(3) indicates the bank must file a Designation of Exempt Person form (Treasury Form #TD F 90-22.53) within 30 days after the first cash transaction in excess of $10,000 between the bank and the customer that is sought to be exempted.