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Managing CTR Exemptions

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Question: 
If we are changing a Phase I to a Phase II exemption, would we do an Amendment so the initial designation date remains the same or would we do an initial designation so we have a different designation date when we file the DOEP?
Answer: 

I'd recommend doing it cleanly by filing a new initial exemption form. I don't have a lot of faith in the database's ability to search out and amend existing designations.

First published on BankersOnline.com 1/31/11

First published on 01/31/2011

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