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CTR Exemption for a Church

I've been in banking for many years and cannot recall ever having a church on the exempt list for CTR filing. I have a branch requesting that their local church be considered. I am unable to find anything in the FFIEC Manual stating specifically that we cannot, but for some reason I don't feel right about it. Are you able to provide me some guidance?

Answer by David Dickinson:I've seen many churches exempt from CTR filing. I am not aware of any guidance from FinCEN or the FFIEC Manual. If the church generates cash from giving, sales at their bookstore, etc., why wouldn't they be exempt? Conduct due diligence on the church, just like you would any other business.


Answer by John Burnett:As I recall, one concern with exempting religious organizations is the requirement in Section 103.22(d)(2)(vi) that a Phase II exempt person be a "commercial enterprise." There are parts of the activities of many religious organizations that might be termed commercial, in that they sell goods or services to provide funding for the organization and its programs. In addition, if significant parts of the organization's income derive from gaming (bingo, Las Vegas nights, etc.), you'd have to ensure that receipts from those sources don't exceed 50% of the organization's receipts, so I can see why one might question an exemption for such an organization based on a strict reading of the regulation.

First published on 2/15/10

First published on 02/15/2010

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