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CTR Exemption Extends to New Business?

Answered by: 
John Burnett

Question: 
We have a customer who is exempt from CTR reporting for the five convenience stores they own. They have opened an additional convenience store. Is it necessary to wait 12 months before exempting the new store or can that added account become exempt immediately?
Answer: 

Assuming that all of the stores, including the new one, are owned and operated by the same entity (meaning they aren't separate corporations owned by the same individual) the exemption you already have on the books covers the new account. If, however, you're looking at six separate entities (corporations, LLCs, etc.) with common ownership, each entity has to stand on its own with regard to exemptions.

First published on BankersOnline.com 3/05/07

First published on 03/05/2007

Filed under: 
Security
Filed under security as: 
IT
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