Exemption Rules for Phase II Requirements

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Question:

I exempted a customer last year after they met the Phase II requirements. Should I file on them this year until they meet the frequent transaction requirement of five transactions or are they exempt until they do not meet them for this year?

Answer:

You are required to review a Phase II customer on an annual basis. If they no longer meet the exemption requirements at the time of the annual review, you would then begin to file CTRs on that customer again.

First published on BankersOnline.com 6/24/13