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Exempt Non-Listed Business: Savings Acct. CTR

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Question: 
Are savings account transactions considered exempt from CTR reporting for the business customer that is an exempt non-listed business? What about cash payments to a loan account? From 31 CFR 1020.315: The exemptible accounts of a non-listed business or payroll customer include transaction accounts and money market deposit accounts. From Federal Reserve Act 19(b)(1)(C): The term "transaction account" means a deposit or account on which the depositor or account holder is permitted to make withdrawals by negotiable or transferable instrument, payment orders of withdrawals, telephone transfers, or other similar items for the purpose of making payments or transfers to third persons or others. Such term includes demand deposits, negotiable order of withdrawal accounts, savings deposits subject to automatic transfers and share draft accounts.
Answer: 

Savings account and loan transactions are not exempt for a Phase II customer.

First published on 09/09/2018

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