A little embarassed by this question. Our Audit team made us aware that BSA Phase II exemptions aren't by account number any longer but by EIN, if the bank so chooses.

I just can't seem to find where they are quoting this information from! I am going to re-read the reg again, but I was hoping someone in our forum might know off the top of their head where I can find that quote.

This is a test post

You would file the DEP form 110 using the TIN (there is no other option), however, only transaction accounts can be exempt from CTRs. Any cash exchanges, or cash transactions to savings accounts would still be reported.

GP is correct. There are no provisions to exempt specific accounts on Form 110.

That was my thoughts but I began second guessing myself. Thank you for your assistance.