Dropping a Customer from Exempt List

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Question:

We have a customer that has been on our exempt list since October, 2004. As of November 15, 2004 their deposits have dropped under the $10,000 reporting threshold. Do I have to remove them from our exempt list? According to our branch where they deposit, the manager complains about our fees often. We assume they may be taking some of their deposits elsewhere. If I don't have to remove them from our exempt list now, how long do I let it go before I should?

Answer:

Exempting a customer from currency transaction reporting is a voluntary process and can be revoked at any time. Typically, banks review a company’s exemption status at least annually to make sure they had enough CTR’s (FinCEN guidance suggests 8 or more in one year). Seeing how you just exempted this account in October, you might want to wait a few more months to see if their deposit amounts increase.

First published on BankersOnline.com 2/7/05