Is it common practice to exempt an MSB from CTR reporting? I have a customer that is a reputable grocery store that performs wires and money order sales. At initial account opening it was indicated that less than 8% of their business consists of the above activity. I know that I am able to exempt them, but is it common to? We are filing CTR's daily.

Thanks for your input!

It was common with my former bank & my current bank. But we only exempted Grocery Stores (like what you described)

One thing auditors liked to see was I had a copy of their sales (from their accountant) that proved the 8% (or whatever percent less than 50%)

They also liked that I had a documented site visit - where I described the customers & what they were purchasing.

Phase II exemptions aren't based on sales volumes, they are based on revenues. Make sure you are documenting the income base of your customer's exemptible vs. non-exemptible business activities.

"A business that engages in multiple business activities may be treated as a non-listed business so long as no more than 50% of its gross revenues is derived from one or more of the ineligible business activities listed in this paragraph (d)(6)(viii)."