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Exempting Customer From BSA Reporting (CTR)

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Question: 
When you exempt a customer from BSA reporting, can you exempt all their transaction accounts even though only one is showing routine reportable activity?
Answer: 

You exempt a customer and not a single account, with the following caveat:

(9) Exemptible accounts of a non-listed business or payroll customer. The exemptible accounts of a non-listed business or payroll customer include transaction accounts and money market deposit accounts. However, money market deposit accounts maintained other than in connection with a commercial enterprise are not exemptible accounts. A transaction account, for purposes of this section, is any account described in section 19(b)(1)(C) of the Federal Reserve Act, 12 U.S.C. 461(b)(1)(C), and its implementing regulations (12 CFR part 204). A money market deposit account, for purposes of this section, is any interest-bearing account that is described as a money market deposit account in 12 CFR 204.2(d)(2).

First published on 01/08/2017

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