I have a customer who had been exempted under Phase I because they are a publicly traded company. Now I've determined that they are a locally owned franchise, not a corporate owned store, and thus not elgible for the Phase I status.
They have enough transactions to be exempted under Phase II, and submitting the correct paperwork is easy enough.
My question is whether or not I need a backfiling determination for all the CTRs not filed while they were incorrectly exempted under Phase I?
_________________________
Opinions are mine and not necessarily those of my employer