"Frequently engages in transactions in currency with the bank in excess of $10,000;"

Second guessing myself here...We have a customer who individually deposits $3000-5000 roughly, per business day, so on Mondays their 3 deposits aggregate to CTR filing. Does EACH transaction have to be over $10,000 to be Phase II exempt, or do the aggregate deposit days meet the criteria for exemption? I am having trouble finding guidance on the definition of "transaction" and aggregation for the purpose for exemptions.

Example:
12/20/21 Deposit including $3500 cash
12/20/21 Deposit including $4500 cash
12/20/21 Deposit including $5500 cash

Does $13500 for the day equal 1 transaction over $10000 for the purpose of exemption?

Yes, multiple transactions that are reportble due to aggregation rules count towards one of the five for your 12-month review period.

Yes, my only Phase II is the same. Mostly the 'weekend' deposits put them over $10g. Right now there are up to a total of 55 for the year.