In reality, you don't exempt them. You verify that they are a bank and entitled to the exemption given to them in the regulation. All you have to once you've done that is add the bank to your exemption list so you don't have to go through the exercise again later.
I agree. You verify that they are a bank and add them to the list. My point was that you can't just go off the idea that all banks are exempt and so you don't have to file any CTR's. That's not the case. You may not have to go through a formal exemption process with a DOEP, but you still have to acknowledge that you've exempted them by adding them to the list. Unless you do that, you should file a CTR.
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