After recently taking over as BSA Officer, as I am reviewing our exemption list, I noticed we have a school district that aggregated over 10,000.00 on one particular day and a ctr was generated. If they are considered a govt entity and should have been exempted, what course should I take? What date should I use for the exemption designation?

A government entity is automatically an exempt person; you do not need to file a DOEP form. The error was in filing the CTR.

Thank You. Another question...
I am trying to determine what date to use on an exemption revocation for a bank on our exemption list. We haven’t used them in years for getting cash. I can’t determine the last time we did. Also, they changed their name in 2011. Please advise.

What revocation? Banks are automatically exempt, just like government entitites.

So if we are not doing any business with them, I can just take their name off our list?

Your list is your list and no one should tell you what should be there. Many banks keep banks and government agencies on their list just so tellers will know not to file on them, but if you're not doing business with them there really isn't any point in leaving them there.

Since I am on a roll here with stupid questions, which I am not afraid to ask, lol...one more...What about a Phase I listed company? Their accounts are now closed. My predecessor has an initial designation on file. Do I need to do a revocation on them? If so, would I use the close out date? Thanks for your help.

Good discussion here. The instructions to the new DOEP also indicate that filing a revocation is discretionary. My only suggestion is that you be consistent, file them all the time or do not file them at all.