CTR Exemption

We have a customer that are currently exempt. We are waiting for the customer to provide the remaining documentation so we can finish our due diligence. The DOEP was filed on 09/24/2018. What is our drop dead date for completing our review so this customer can remain exempt?

Thank you.

Prior to filing the exemption?????

This is a newer exemption where the DOEP was filed last year on 09/24. If the customer does not get us the requested documentation, do I start filing CTRs again on 09/25/2019?

What documentation would you need from the customer?.... Unless your process is relying on them for eligible activity %s of business related to lottery/etc.... I conduct my own review of their accounts to determine that activity. Never had any issues with exams or auditors.

I do the same as praBSA, because the customer normally does not even know they are exempt. We exempt them based on our review.

Same as the two above, can't imagine why a customer would hold up an exemption.