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University Health Science Center Account

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Question: 
We have an account for a state university's health science center (not the main university). Would that be considered public funds? If not, can we exempt them from CTR reporting?
Answer: 

The interrelationships between campus entities can be complex, and it's not automatic that the health science center is a division of the university. You need to find out if the center is 100% part of the university organization. If so, and if you have determined that the university is a government entity, you should be OK declaring the center exempt.

If you already have the university itself exempted, and the center is nothing more than a piece of the university, you may not need to separately exempt the center. Instead you could include it under the university's umbrella. Check the organizations' EINs for a clue.

Do you reasonably expect the center to have cash transactions such that an exemption is desirable? What cash activity would a health science center expect to transact?

First published on BankersOnline.com 6/23/08

First published on 06/23/2008

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