Answer:
Let's start by clarifying "exempt account" and "not exempt account."The exemptions under 31 CFR 103.22(d) are of customers, not accounts. However, there are accounts under a Phase II exemption that aren't covered. For example, if a grocery store is exempted, but the store accepts donations for the American Hangnail Association -- a charity made up for purposes of illustration here -- and deposits those donations in cash to an account the store set up and controls for those donations, the store's standard deposits to its own accounts would be exempt, but any cash deposits to the Hangnail Association would not be exempt.
Assuming that the store's cash deposits on a given day include $28,000 for its own accounts and $3,000 for the Hangnail account, no CTR is filed because you ignore the $28,000. If the cash deposits are $24,000 to the store's own accounts and $12,000 to the Hangnail Association account, you file a CTR for $12,000 (again, ignoring the cash deposited under the exemption).
First published on BankersOnline.com 4/03/06
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