Answer:
One of the best things you can do is create an Exemption Checklist and place a copy in each file folder.
The “Initial Exemption Checklist” could include items such as:
- Has the customer been with the bank at least 12 months
- Has the customer had greater than 8 CTR transactions in the last 12 months
- Copy of the TDF form
- Has the account been reviewed for suspicious activity, if so what were the findings
- Articles of Incorporation (to include signers)
- Explanation of the exemptions primary business
The biennial checklist can be very similar to the Initial Checklist and could include some additional questions that might impact its exemption status:
- Are there any new accounts added or deleted, if so what type of accounts are they
- Has there been any change in ownership or Employer Identification Number (EIN)
First published on BankersOnline.com 12/6/04
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