Phase II Exemptions

Posted By: Likes to Comply

Phase II Exemptions - 10/26/11 07:57 PM

Can all "eligible accounts" for a customer be exempted for CTR purposes if one account has cash transactions in excess of $10,000 or only the "eligilbe accounts" individually that have transactions more than $10,000 in cash transactions?
Posted By: Likes to Comply

Re: Phase II Exemptions - 10/26/11 09:32 PM

Maybe I need to ask this differently. If a customer has two DDA accounts and when the cash transactions are aggregated the > $10,000 threshold is met, can this customer be exempted from CTR filing? Or would the threshold have to be met on each individual account?

This is of course assuming all the other criteria for Phase II exemptions is met.
Posted By: cbinder63

Re: Phase II Exemptions - 10/26/11 09:47 PM

The exemption should be by TIN. All exemptable accounts under the TIN qualify.
Posted By: Likes to Comply

Re: Phase II Exemptions - 10/27/11 03:50 PM

Thank you!