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#1744936 - 09/27/12 07:19 PM CMIR - FinCEN 105
Juby Offline
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Is a bank ever required to complete a CMIR if the bank itself is sending or receiving the the currency or monetary instrument? Or is the bank always exempt?

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#1744941 - 09/27/12 07:25 PM Re: CMIR - FinCEN 105 Juby
Elwood P. Dowd Offline
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Elwood P. Dowd
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"Exempt" is not quite the right word.

The filing requirement just does not apply to banks when it's the customer who moved the money; 1988 - R002.
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#1744957 - 09/27/12 07:39 PM Re: CMIR - FinCEN 105 Juby
Juby Offline
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So if, for example, a foreign loan customer mails us a check for over $10,000 to be applied as a loan payment. It is still on the customer?

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#1744962 - 09/27/12 07:46 PM Re: CMIR - FinCEN 105 Juby
Elwood P. Dowd Offline
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Elwood P. Dowd
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Posts: 21,939
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From the instructions:

Exceptions: Reports are not required to be filed by:
(1) a Federal Reserve bank,
(2) a bank, a foreign bank, or a broker or dealer in securities in respect to currency or other monetary instruments mailed or shipped through the postal service or by common carrier
[abridged]
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1744964 - 09/27/12 07:47 PM Re: CMIR - FinCEN 105 Juby
Juby Offline
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Joined: Jul 2009
Posts: 218
Thank you.

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