I have read through Kirchmann and the IRS documentation for the TD F 90-22.53 but don't find the answer to my question.

We are preparing the biennial renewal forms. We have a customer who doesn't appear to be eligible for exemption. We did our annual review and the business had very few reportable transactions. Since this is a biennial review, does that exemption just expire or do I need to file a TD F 90-22.53 as "exemption revoked"?

Thanks for your help.

According to the instructions, you are not required to file the form to revoke an exemption. That being said, I personally think it's a good idea, as it demonstrates the effectiveness of your review process. Also, documenting the date of revocation will prevent any future speculation regarding the backfiling of CTRs.

Filing the Designation Form to revoke an exemption is optional. Not sure why they even bothered to put that option on the form.

Just make sure you do whatever you need to do in-house to restart the process of filing CTRs.

If filing the Designation Form for the revocation makes someone in your organization happy, humoring them might be a good course of action. But it's not required by the "rules."

While doing the Biennial Reviews they discovered that the TIN number was incorrect when it was filed. How should this be handled? Should an amended TD F 90-22.53 be filed? And if so do the transactions that were exempted before with the incorrect TIN need to have a CTR filed? Thanks>