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CTR, Exempt Person Form, and Reportable Transactions

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Question: 
If we completed a Designation of Exempt Person form on 81203, but didn't approve it until 81903 and during that period another transaction occurred that would normally result in the completion of a CTR, are we still required to complete one? The CTR we are using for our initial basis of exemption occurred on 81103.
Answer: 

As long as you filed the Designation of Exempt person form within 30 days of 8/11/03, the date of the first transaction you sought to exempt, none of the transactions are reportable. Follow this link to FinCEN Advisory #10 and see question 7.

First published on BankersOnline.com 10/20/03

First published on 10/20/2003

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