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 BankersOnline.com 6/27/11