Answer:
Answer by Randy Carey:You should revoke the Phase I exemption and start filing CTRs. If they qualify for a Phase II exemption, you can file a Phase II exemption after 12 months.
Answer:
Answer by John Burnett:You can use the customer's cash activity during the most recent twelve months (assuming they've been with you at least one year) in a decision whether to file a Phase II Designation of Exempt Person now. When you do so, however, make sure you don't include non-exemptible transactions (if there were any), such as currency exchanges, loan payments, etc.
First published on BankersOnline.com 5/05/08
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