When the annual CTR exemption review is performed, what do we do if we find out one of our customers is no longer exempt? Do we just start filing from the annual review forward or do we need to determine the point in time when the exeption no longer applied and complete CTRs from that point until the review date?

It probably depends on how far back you would have to go and how many you would have to file. And why their exemption no longer applies. A call to FinCEN may be the way to go, give them your specifics and see if they recommend back-filing or not.

No - if you find this at the time of the annual review, you just start filing. That is why there is an annual review.

I felt the logical thing to do would be to file from the review forward - hence the annual review process. But logic doesn't always prevail in compliance....