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#1982411 - 12/11/14 03:14 PM EDD on CTR exemption
Tom Owen Offline
Junior Member
Joined: Nov 2014
Posts: 43
PA
We have been compiling more EDD on our exempted businesses. Curious as to what most banks compile for their review process, especially with purely deposit customers with no credit or lending relationship with bank, we have no financials on record. Any insight or feedback is appreciated.
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#1982426 - 12/11/14 03:36 PM Re: EDD on CTR exemption Tom Owen
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I have to counter with this question: To what end are you expanding the amount of information you're gathering for the exemption review process?
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#1982438 - 12/11/14 03:49 PM Re: EDD on CTR exemption Tom Owen
Tom Owen Offline
Junior Member
Joined: Nov 2014
Posts: 43
PA
During our annual review of our exempts, we had been primarily focusing on the transactions, that it met criteria. We are now compiling more EDD in which to ensure exempts to do not have ineligible business activities over 50% of gross revenue. (Example beer distributor that sells lottery tickets, or grocery store that issues money orders.) But basicly showing that we have obtained enough EDD to be comfortable that the business is not engaging in any ineligible business activities and is supporting their stated business activities.

During CTR reviews, what information do you examine?
-transaction history
-financials to show business activity
-....

or do most banks predominately just examine transaction history and sufficient CDD/EDD that business has no ineligble activities?
Last edited by Othom; 12/11/14 03:52 PM.
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