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When to File Exemption Form (Phase II Non-Listed)

When exempting a Phase II non-listed business, at what point can the exemption form be filed? Should it be filed after the 5th CTR is filed (when the 6th reportable transaction occurs) or can it be filed in lieu of the 5th CTR?

Answer by: Randy Carey Asked and answered


Answer by: David Dickinson Footnote 79 to the FFIEC BSA Exam Manual states "after the customer has within a year conducted 5 or more reportable cash transactions." I interpret the rule to mean they need to have 5 CTRs filed and then they qualify for the exemption (in lieu of the 6th CTR).


Answer by: John Burnett And, you must file the DOEP within 30 days of the first CTR you wish to exempt. So, if a 6th reportable transaction occurred on 6/1/11, you have until 7/1/11 to get the DOEP filed and you won't have to file the CTR for the 6/1/11 transaction. Just make sure you indicate on the DOEP that the exemption effective date was 6/1/11.

First published on 6/27/11

First published on 06/27/2011

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