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#88324 - 06/16/03 02:35 PM CTR re-exemption
Anonymous
Unregistered

Are we required to file a re-exemption form on government entities?

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BSA/AML/CIP/OFAC Forum
#88325 - 06/16/03 04:10 PM Re: CTR re-exemption
Anonymous
Unregistered

NO

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#88326 - 06/16/03 04:16 PM Re: CTR re-exemption
Anonymous
Unregistered

Do you have them organized on your exemption list as a Phase I or Phase II exemption? I believe Phase II exemptions require a bi-ennial renewal on their exemption status. You may want to check the instructions for completion of TD F 90-22.53. I do not believe Phase I exempt persons require this.

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#88327 - 06/16/03 04:33 PM Re: CTR re-exemption
Kansayaku Offline
Diamond Poster
Joined: Jan 2003
Posts: 1,454
metsuretsu
Government entities are considered under Phase I exemptions. As thus, there is no obligation to re-file. {Sec. 103.22(d)(5)(i)}

(This is assuming that the original filing was completed correctly.)
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#88328 - 06/16/03 05:57 PM Re: CTR re-exemption
Anonymous
Unregistered

Yes, they are filed as a Phase I exemption. The previous audit I was referring to listed the re-filing as an exception and I couldn't find anything requiring re-filing of the exemption form for gov't entities. Thanks to everyone for their input.

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