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#623267 - 10/11/06 07:11 PM CTR Exemption Annual Review
Ibex Offline
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Joined: Oct 2006
Posts: 1
The regulation governing CTR exemptions requires that each exemption be reviewed annually. Do the readers of this board understand this to mean that the item should be reviewed a) once each calendar year or b) that they must be reviewed once during any given 12 month period?

For example, if a review is performed in January of 2005 and in February 2006, is the second review compliant or is there a violation because it was greater than twelve months? For the sake of simplicity, let’s say that our customer has a Phase I exemption (i.e., no renewal to consider).

Thank you in advance for your feedback.

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#623268 - 10/12/06 04:17 PM Re: CTR Exemption Annual Review
Dip Offline
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Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
My advice would be define it yourself and add your definition to your policy and procedure. In any case, I wouldn't let the review go longer than 12 months. For example, if you define annually to be once per calendar year, you could technically go nearly two years without having a review (January 2005 and November 2006 = nearly 2 years). Maybe do the annual review on each exempt's anniversary?
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#623269 - 10/12/06 05:15 PM Re: CTR Exemption Annual Review
Anonymous
Unregistered

Since the filing must be done prior to March 15, I do all my annual reviews in January/February. Just makes it easier in my opinion.

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#623270 - 10/12/06 05:14 PM Re: CTR Exemption Annual Review
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
Quote:

Since the filing must be done prior to March 15, I do all my annual reviews in January/February. Just makes it easier in my opinion.



Me too.

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#623271 - 10/12/06 06:04 PM Re: CTR Exemption Annual Review
Dip Offline
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Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
Quote:

Quote:

Since the filing must be done prior to March 15, I do all my annual reviews in January/February. Just makes it easier in my opinion.



Me too.



this doesn't apply to phase I exemptions
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#623272 - 10/12/06 06:45 PM Re: CTR Exemption Annual Review
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
Quote:

Quote:

Quote:

Since the filing must be done prior to March 15, I do all my annual reviews in January/February. Just makes it easier in my opinion.



Me too.



this doesn't apply to phase I exemptions



True, but I do them at the same time. I find it easier to review them all at once. Then I send the biennial designations for those that need it. We have 31 exemptions, 12 of which are Phase I.

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#623273 - 10/12/06 07:35 PM Re: CTR Exemption Annual Review
#12 Offline
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Joined: Jun 2005
Posts: 1,343
Quote:

Quote:

Quote:

Quote:

Since the filing must be done prior to March 15, I do all my annual reviews in January/February. Just makes it easier in my opinion.



Me too.



this doesn't apply to phase I exemptions



True, but I do them at the same time. I find it easier to review them all at once. Then I send the biennial designations for those that need it. We have 31 exemptions, 12 of which are Phase I.



I do my review the same way Kelsey D!
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#719631 - 04/20/07 06:46 PM Re: CTR Exemption Annual Review #12
La. Lady Offline
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La. Lady
Joined: May 2001
Posts: 1,873
What do you use as the review documentation for banks or credit unions...... or is it not necessary to review those.....
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#719702 - 04/20/07 07:23 PM Re: CTR Exemption Annual Review La. Lady
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Exemptions in general, Phase I and Phase II, must be reviewed annually and the only reasonable interpretation means that's every 12 months. A competent outside analyst will expect that the review will be documented. The easiest way to document the existence of a bank is to find it on Bank Find on the FDIC's web site, print out the page, and attach it to your review sheet. (Your browser should show the date printed at the bottom.) I don't have a pat answer for credit unions, but will amend this post if I find it.

Generally, it is not necessary to do an annual review of a government entity if the name of the entity clearly indicates it is governmental. (I'd appreciate hearing from anyone who has been told something else and exactly what it was you were told.)

Voila: Find a Credit Union
Last edited by Ken_Pegasus; 04/20/07 07:34 PM.
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