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Exempt Non-Listed Business: Savings Acct. CTR

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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.

If the savings account is subject to automatic transfers or otherwise able to be used to make third-party payments, it may be included within that exemption. For example, an MMDA is likely to qualify. Regular business savings account may not qualify if ACH debits aren't accepted for the account and bill payments aren't permitted from it.

As for cash payments to a loan account, they are never covered by the "Phase II" exemption for non-listed businesses. The exemption only covers cash transactions (deposit and withdrawals) in their qualified deposit accounts. You didn't ask, but a cash-to-cash exchange (such as a cash payment for a change order) is not exempted, and must be reported if non-exempt transactions meet the reporting amount threshold.

First published on 04/21/2019

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