On December 4, 2018 a CTR was filed for XYC company. No transactions requiring a CTR filing were conducted on December 5.
On December 5 it was determined that the company qualified for a Phase II exemption and the DOEP was filed.
The regulation states the DOEP needs to be filed "...within 30 days after the first transaction in currency that the bank plans to exempt."
Did the bank file too soon? If we filed a CTR on December 4 it doesn't seem like the bank planned to "exempt" that transaction. Should the DOEP filing have occurred on or after the next date a CTR would have been required but was not filed?
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