This is a reminder that as of July 1, 2000, depository institutions must use the reformed Currency Transaction Report ("CTR") exemption regulations for exemptions established prior to October 21, 1998 as well as exemptions established after that date, in accordance with 31 C.F.R. Part 103.22 (d)(2). This means that depository institutions must have designated a customer as an exempt person by filing the Designation of Exempt Person Form (TD F 90-22.53). If an institution established an exemption by filing a "zero" CTR with box 36 marked "Designation of Exempt Person" and provided the other required information, it does not need to file a TD F 90-22.53 form to exempt the same customer.
Depository institutions are encouraged to exempt all eligible customers and to use the reformed CTR exemption regulation as soon as possible. It is preferable that you file the TD F 90-22.53 form to exempt customers (rather than filing a "zero" CTR), which is available in paper copy or through magnetic media filing. Please note that as of July 1, 2000: (i) the TD F 90-22.53 form will be the only means to exempt a customer; and (ii) all special exemptions become obsolete and cannot be relied upon to exempt a customer.
FinCEN’s Advisory No. 10, "Reformed CTR Exemption Process: Questions & Answers" (October 1998), which provides guidance on the use of the reformed CTR exemption regulations, is available by calling the IRS-Enterprise Computing Center-Detroit Hotline at 1-800-800-2877. Bulk orders (10 or more) of the TD F 90-22.53 form are available by calling the IRS Forms Distribution Center: 1-800-829-3676. FinCEN’s Advisory No. 10 and the TD F 90-22.53 form are also available from FinCEN’s web site at https://www.fincen.gov, under "Publications" and "BSA Forms", respectively.
If you have any questions concerning CTR exemptions, please contact the IRS-Enterprise Computing Center-Detroit, Compliance Review Group, at 1-800-800-2877, and a Bank Secrecy Act representative will assist you.
To view the Supervision and Regulation Letter (SR 00-12(SUP)) issued on July 5, 2000 by the Board of Governors of the Federal Reserve System to each Federal Reserve Bank on revised examination guidelines for the reformed CTR exemption procedures, visit web site at: http://www.federalreserve.gov/BoardDocs/SRLetters/2000/SR0012.HTML.