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How to Exempt Agent from CTR Reporting

We have an armored car service that is acting as an agent for 3 different area businesses and delivering their deposits to the bank. We know that the transactions are CTR reportable over $10000, as they share the same transactor and that the July 2009 FinCEN Guidance indicates that we would need to gather the transactor's personal detail (not just mark Armored Car), but...Is there anyway to exempt the Armored Car company from CTR reporting? (We can't think of one, but we are looking at 50+ CTRs a year that would need manual merging in our processing system.)

Answer by Randy Carey: Exempting the agent would not be possible.


Answer by John Burnett: Have you reviewed the individual businesses involved to see if they might qualify for exemptions under Phase II rules? If none of them would trigger a CTR filing at least five times a year except when aggregated at the armored car courier conductor level, the answer is No. But if one or more of those businesses is exemption eligible, it could reduce the number of times you'd need to file when these deposits are brought in.

First published on 5/28/12

First published on 05/28/2012

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