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Combining Business As 1 Designation of Exemption?

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Question: 
I am seeking some guidance regarding the designation of exemption for a customer that mutually owns two businesses and conducts activity for both with our bank. He is a common owner listed on both accounts and therefore CTRs have been filed on both businesses on a single Currency Transaction Report by selecting the multiple persons and combining both businesses' aggregated transactions for reporting.The two businesses have separate accounts and tax ID numbers, the addresses and phone numbers listed are different as well. Transactions do not intermingle between the businesses and are clearly separated; the only common denominator is one of the principal owners of the businesses.When attempting to exempt the businesses can they both be combined under one Designation of Exemption? If not, only one of the businesses qualifies on its own to be exempt, would we be required to amend prior Currency Transaction Reports to separate the two businesses? Or have we been filing incorrectly to begin with?

First published on 04/22/2013

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