CTR Exemptions Eased; Shameless Plug
Last week, FinCEN issued a final rule that should make the exemption process a bit easier for financial institutions. Access the final rule here.
The final rule makes the following changes:
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Credit unions will no longer be required to review annually or make a designation of exempt person (DOEP) filing for entities who are other depository institutions, U.S. or State governments, or entities acting with governmental authority. These are those Phase II exemptions. This is good stuff. So, for example, if you won't need to exempt your corporate credit union for your cash shipments.Â
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Credit unions will be able to designate an otherwise eligible non-listed company or a payroll "customer" after either two months time (previously twelve months) or after conducting a risk-based analysis of the legitimacy of the member's transactions.Â
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FinCEN's guidance on the definition of "frequent" transactions will be changed to five transactions per year instead of the current eight transactions per year.
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Credit unions will no longer be required to biennially renew a designation of exempt person filing for otherwise eligible Phase II member, but an annual review of these customers must still be conducted.
All these changes are great, and they will come quickly. This rule goes into affect 30 days after the Federal Register gets around to publishing this. Here's another thought: the changes will definitely require an amendment to the BSA Manual. I wonder if they will due a surgical strike to simply amend the exemption portion, or whether they will take advantage of the opportunity to make other edits to the manual. I'll let you know if I hear anything.
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NAFCU does a lot of webcasts. And most of them are directed at you compliance junkies. Next year, we're offering an annuual subscription. If you subscribe to a lot of our webcasts, this is a great way to save money by registering once, rather than having to pay for each webcast separately. Again, the cost savings is substantial.Â
NAFCU members, for example, would pay $2,500 for an entire year. That's a savings of $1,700. Non-members would pay $3,500, which is a savings of $1,900.  If you want additional details, go here.