If we have a customer who no longer meets the requirements to be exempt (has not had 5 reportable transactions in the last 12 months), do we still have to send in the "DOEP" to revoke or do we just start filing CTRs again?

Thank you!

From the preamble to the new exemption rules:

"In light of these comments and FinCEN’s own research on the utility of this information, at this time FinCEN is not making the reporting of a revocation mandatory in the final rule."

But you can if you wish.

I knew I had read that, but for some reason I couldn't find it again.

Thank you!