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#2218062 - 07/19/19 05:17 PM Designation of Exempt Person Form filed too soon?
dottiec Offline
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Joined: Jul 2007
Posts: 305
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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#2218086 - 07/19/19 08:52 PM Re: Designation of Exempt Person Form filed too soon? dottiec
rlcarey Offline
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rlcarey
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Galveston, TX
If you wanted to exempt all transaction from Dec 5th forward, then filing on Dec5th is within 30 days whether a transaction occurred or not.
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#2218109 - 07/22/19 01:02 PM Re: Designation of Exempt Person Form filed too soon? rlcarey
dottiec Offline
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Joined: Jul 2007
Posts: 305
Thank you, that was the answer I wanted.
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