CTR ReExemption Form: What are the consequenses of failure to file?

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Question:

We were to have sent in a reexemption on one of our customers in March. We cannot find a copy of the form and we are not able to tell from our records if we sent it or not. 1st How do we find out if we sent the form? 2nd If the form was not sent, do we now have to file CTR's for the entire year?

Answer:

Contact the IRS Detroit Computing Center to request confirmation of the form. You may have to pay a nominal research fee, but it will be much lower than the penalty for failure to file the CTRs. If you learn that it was filed, breathe a big sigh of relief. Otherwise, you must immediately conduct a 100% audit of all exemptions. The purpose of this audit is twofold: one, to assure that your documentation confirms that remaining DEP forms were filed on scheduleyou don't want to correct one and then find more surprises later, and two, to gather all necessary info about the transactions and aggregates that should have been reported since your previous DEP expired. After you have gathered all relevant information about any and all exemption errors, contact FinCEN to explain what happened, offer to backfile and hope for the best.

First published on BankersOnline.com 2/17/03