We are bank A. On occasion we purchase some foreign currency from our correspondent bank, Bank B. We call, they send it the next day delivery. So, we now have peeps saying a CTR should be filed...as we didn't file an exemption for B. isn't this stretching things a little? Guidance please....and any link you can provide that addresses this (I thought this was covered in a thread once a year or so ago but...)

You have 30 days to file an exemption from the date of the transaction :o)

Page 2 of the instructions

http://www.fincen.gov/forms/fin110_dep.pdf

Any bank that wishes to designate a customer
as an exempt person must file FinCEN Form 110,
Designation of Exempt Person, with the IRS Detroit
Computing Center no later than 30 days after the
first transaction to be exempted.

Item 2--Effective date of the exemption. For initial
designation, enter the date of the first transaction to
be exempted.

(not as) so, from your understanding of our situation, we should file an exemption notice on the correspondent bank. In the interim, we have to file a CTR on ourselves as we purchased the money????

You dont need to file on your bank. Simply file a Form 110 Phase I exemption on the other bank. Transactions between banks are basically exempt but you do need to do a one-time filing. Then simply do an annual review every year on the bank by verfying that all their info is the same. This review does not need to be filed with FinCEN.